12. d. continue to provide and publicise free and anonymous ways of reporting bribes; e. work with MDAs to provide robust responses to citizens’ reports, and to demonstrate that citizens’ actions are making a diff erence; f. put in place measures to ensure that as far as possible lower level public officials receive their salaries in full and on time ; g. improve the supply of all goods and services due to local health and education facilities , so that public sector worke rs can do th eir jobs with dignity an d achieve job satisfaction h. work with MDAs and IMC to train public officials to begin a process of culture change in relation to challenging the system of taking bribes.

5. Focus group p articipants identified three principal reasons for paying a bribe: to obtain a service, to speed up formalities or to overcome an infringement or offence . 2.2.1. Accessing services Afrobaro meter data and the PNB Baseline Survey indicate that bribes to access services are paid in the five PNB sectors of focus. Health services in Sierra Leone should offer free under - five child health care, and antenatal and postnatal care, and children should have access to 9 years of free education from about age six. In practice, however, charges are levied for seeing a nurse or a doctor and/or for buying medicines that should be free, and for enrolling children in primary and secondary school, entering and p assing exams and obtaining a report card. According to the PNB Baseline, approximately 50 per cent of citizens regularly pay for health services that should be free, and approximately 55 per cent for education services. 37 Within the power and water services sectors, bribes were found to be paid to avoid more expensive charges (such as buying a meter and connection fees) 38 . Police often ask for money from citizens to carry out services such as arresting and transporting suspects to the police station, and taki ng/recording statements. 2.2.2. Paying a bribe to speed up formalities Participants in the PNB FGDs described this as ‘speeding up procedures and avoiding wastes of time’ and examples were cited in the water and power sectors to obtain preferential treatment in relation to grid and supply line connections and in relation to repairing faults and carrying out maintenance. Cross - border traders have also described having to pay bribes to avoid hold - ups and formalities at border crossings. 39 2.2.3. Paying bribes to overcome an infringement Members of the public pay bribes to the police for avoidance of penalties upon breaking the law, and PNB focus group participants provided several examples of paying bribes to avoid fines or to avoid being arrested for an alleged wrongdo ing. This is a particular complaint of the Ocada riders (motorbike taxis) and transporters who complain that the police harass them until they find something wrong with the vehicle or their licenses, and although many of the ‘fines’ paid are small, they oc cur frequently , even daily . In addition, people gave examples of suspects bribing the police to secure bail after arrest, or be released from prison whilst on remand or after a conviction. 40 The police also operate systems of ‘booking fees’ where they impo se charges each time the transporters ply popular community routes. 2.3. How widespread is bribery in Sierra Leone? Levels of corruption vary by geographical location and by sector, however, and this section explores the extent to which bribery is prevalent in focus sectors in the four PNB pilot districts and two control districts. 37 Charges vary by district and urban/rural lo cation. PNB reporting for October and November puts health ahead of education but citizens reports do not represent a statistically valid sample. 38 Need reference for final version of baseline – title and source 39 Peter Albrecht and Elizabeth Drew; ‘ Security governance in the Mano River borderlands’, http://www.c - r.org/downloads/Accord 22_17Security governance in the Mano River borderlands_2011_ENG.pdf 40 Need reference for final version of Baseline Survey – title and source

7. 2.3.4. Corruption in the Electricity Sector National electricity generation is availabl e only in regional headquarter towns (cities) of Bo, Kenema, Makeni and Freetown and adjacent rural areas in the pilot districts; no electricity is available in the two control districts (Bonthe and Koinadugu). According to the baseline survey, 13.2 percen t of respondents in pilot districts (combined) confirmed that they had paid additional costs. Of these, Kenema district accounted for highest proportion of extra payments at 29.25 per cent , while Western Area recorded the lowest occurrence (2.9%). A signif icant proportion of respondents in Kenema (42.9%) paid less than Le5,000 to access electricity in their homes, whereas in Bombali and Western Area significant proportions of respondents (66.7% and 50.0% respectively) paid between Le20,000 and Le50,000 for the same services. 2.3.5. Corruption in the Police M any citizens encounter the police in their everyday lives , but public confidence in the police is the lowest of all public sectors : the National Corruption Perceptions Survey records nearly 90 per cent of respo ndents as having low confidence levels in the police , for example . 47 The PNB baseline survey asked similar questions and responses varied from over 80 per cent of citizens in control districts having a little or no trust in the police , to o ver 70 per cent f rom Bombali and Western area and over 60 per cent from Kenema and Bo. 48 Unsurprisingly given the se figures , 57.7 per cent of respondents in control districts stated that they had bribed the police recently , compared with s lightly over o ne - quarter of respond ents (26.1 per cent ) in pilot districts . 49 Analysis of PNB c itizen reporting for October and November indicates that payments to the police comprise nearly half of all reports , with traffic offences being by far the mo st commonly reported bribe . To date, ab out three times as many men as women have made reports about the police through PNB reporting systems. 50 2.3.6. Corruption compared: Rural and Urban Areas Analysis of the PNB baseline survey and Afrobarometer data indicates differences between levels of corruptio n and bribe payments between urban and rural areas , but the most marked differences appear between control and pilot areas . The control areas were selected to represent different characteristics than those of the pilot districts and as a result they are m ore rural and more remote from larger reg ional centre towns . The baseline survey indicates that higher bribes tend to paid by citizens in more remote areas. There are exceptions to this, but respondents living in control districts and in the rural areas of the pilot districts report having paid more overall in bribes. This may be due to the respondents’ own lack of awareness/education, or perhaps due to greater pressure on more scarce resources . Extra payments for health services were higher in rural ar eas than in urban areas for both pilot and control districts. Within the pilot districts, slightly more respondents in rural areas (39.5 per cent ) that they paid extra cost s for health services 47 National Corruption Perception Survey 2013 48 Need reference for final version of baseline – title and source 49 Ibid 50 Monthly Data Analysis for PNB Reporting Platform October and November Reports. (Assume these will be available online?)

4. adequate internal control systems’. 29 Corruption levels are unlikely to reduce until these fa ctors are addressed. 2.1.2. Causes of bribery in Sierra Leone: public service delivery officials At the level of the public officials delivering services, petty corruption in not necessarily covert: in some cases, illegal payments a re so widespread that they ca n happen in full view, with officials openly asking for bribes in exchange for services, and citizens openly pay ing without complaining. 30 However, i nterviews carried out for the PNB baseline survey and PNB Pre - launch meetings add detail to the context in w hich many public official s work . Officials describe being driven to bribery through poor conditions of public service, especially minimal salary levels and/or delayed salaries, and shortages of the resources necessary to do their jobs. T ypical quotes incl ude “we have prob lems in running our divisions; f uel supply is irregular; even stationery supply is insufficient; I have to beg for packets of paper from a local store; there is no accommodation for me, no transport and conditions are generally poor; d rug supplies and learning materials hardly reach on time”. 31 Interviews with individual public officials indicated that many of them are unhappy with taking bribes and believe that bribery is unacceptable . 32 They feel they have limited option s , however, due to the reasons above . 2.1.3. Causes of bribery in Sierra Leone: citizens In FGDs for the PNB baseline survey, c itizens stated that accepting bribes is ‘totally unacceptable’, and they were clear about its illegality: “...we don’t know for public officials but for us ordinary citizens, bribery is criminal”. 33 Interestingly they sympathise with the position of public officials, recognising that salaries are often low and may be delayed by several months in some cases , 34 and they put the blame for this on the government “if the blame for bribery comes back to public officials ... it might just be the case that majority of them [bribe takers] are taking bribes [because of] disincentives ... on the part of Government”. 35 Focus group participants provided useful perspectives on how bribes are paid. They stated that it is usually the ‘bribe givers’ (i.e. citizens, the ‘victims’ of corruption) that initiate bribery by offering a bribe, but that ‘bribe takers’ (corrupt officials) often act in ways that create an environment in whic h citizens are encouraged to offer bribes in order to speed up access to the service in question. Respondent s therefore believe that the power to stop or reduce bribery requires a change in behaviour of both service beneficiaries – bribe givers - and publi c officials – bribe takers. 36 2.2. Why do people pay bribes? 29 Ibid 30 Coffey International; ‘Pa y No Bribe Campaign Prelaunch Monitoring Report ’ 2016 31 ‘Pa y No Bribe Campaign Prelaunch Monitoring Report ’ op. cit.; Coffey PNB Monitoring Report, November 2016 32 Need reference for final version of baseline – title and source 33 Ibid 34 Ibid 35 Ibid 36 Ibid

9. terms of amounts paid. As noted above , in the energy sector in Kenema district , a significant proportion of respondents (42.9 per cent) paid less than Le5,000 to access electricity in their homes, whereas in Bombali and Western Area significant proportions of respondents (66.7% and 50.0% respectively) paid between Le20,000 and Le50,000 for the same service. 58 In the first two months of PNB activity , payments to the police were among the lowest recorded values, with an average of approximately SLL 38,000 59 per bribe during October and November 2016. Analysis of the data indicates that the high numbe r but relatively low value of “t raffic” reports against the police contribute to the lower cost of police bribes overall. T he police recorded the highest number of citizen complaints , however, at 48 per cent of all reports 60 , which reflects a pattern found in many African countries. 2.4.2. Sexual favours Sexual favours are t he s econd most prevalent – but far less frequent – form of payment for bribes. Payment through sexual favours constituted 8 per cent of all reported bribes in e ducation and 4 per cent overall across the five sectors on which the PNB programme is focused. 61 T he e ducation sector may be more vulnerable than other sectors to this kind of unacceptable exploitation since its clients are mainly younger with less access to cash . In addition, interactions between service provider and client typically occur over an ex tended period in education , which may support the building up relationships that support this kind of bribery : i t is a serious problem about which further information should be obtained. FGDs carried out for the PNB Baseline Survey also identified other c ircumstances in which sexual favours are given and receiv ed . Participants stated that sexual favours occur between female subordinates and their male bosses in exchange for job security, or for making up for inefficiencies at work. S exual favours may also be offered by female business people to public officials, especially tax officials, in exchange for services such as favourable tax treatment or other kinds of support. Additionally, female ‘loiterers’ ( commercial sex workers ) and petty criminals may offe r sexual services or cash to police officers in exchange for their release from custody or bail. 62 Reports from Sierra Leone and other coun tries indicate that women cross - border traders are often obliged to provide sexual services to speed up or dispense w ith border formalities in order to be able to carry out their businesses . 63 2.4.3. Other forms of payment On occasions, c itizens offer other types of favours such as animals, food or agricultural products in lieu of cash. Over the first two months of the PNB pro gramme, these bribes 58 Need reference for final version of Baseline Survey – title and source 59 Approximately £5.28 at December 2016 exchange rates 60 Monthly Data Analysis for PNB Reporting Platform October and November Reports. (Assume these will be available online? Please provide reference) 61 Monthly Data Analysis for PNB Reporting Platform October and November Reports. (Assume these will be available online? Please provide reference) 62 Need reference for final version of Baseline Surv ey – title and source 63 Peter Albrecht and Elizabeth Drew op. cit.; see also ‘AREAP Case Study 2: Empowerment Matters’ http://www.tripleline.com/publications.php

11. subjected t o time wasting practices by officials. In the case of the police particularly , citizens fear retaliation or may not feel protected if they report corruption. Sadly, citizens see bribery as a major hindrance to access ing free health care and education servi ces, and recognise that death can be a consequence of failure to access healthcare , which, they are unwilling to risk . 71 Although PNB focus groups were undecided about whether specific groups (male/female, young/old, employed/unemployed, rich/ poor, lit erat e/ illiterate ) were targeted for bribery, t hose with power, status or personal connections can avoid paying bribes . The CAP study demonstrates that not all categories of drivers are equally vulnerable or complicit in paying bribes, and that some, such as Go ve rnment and NGOs drivers were less likely to give money when stopped. Interestingly, no government drivers reported giving money , but i nstead followed du e process (47 per cent); use d personal connections (35 per cent), and in a few cases , plead ed for merc y (18 per cent). 72 More NGO drivers also pursued refusing to pay a bribe , with 60 per cent preferring to plead for mercy, and 27 per cent following due process. Only 13 per cent reported giving money when stopped. Private drivers were nearly evenly split b etween those that preferred to plead for mercy (38.5 percent) and those that paid bribes (40 percent). Clearly drivers who felt they had fewer options were mo re likely to pay a bribe. 3. Conclusions i. Even though bribery is woven into the fabric of daily life , t here are high levels of awareness among men and women in Sierra Leone as to its illegality and unacceptability ; citizens are, however, sympathetic to the plight of public officials who may be trying to deliver services in the absence of necessary resour ces and regular salaries. ii. Public officials themselves know that it is wrong to ask for bribes, to accept bribes or to create situations where citizens feel pressured to offer bribes. They justify it on the basis of minimal salaries, under - resourc ing of fa cilities and poor quality work conditions. iii. C itizens are un likely to support the reporting of bribery unless they feel safe to do so and see that it will make a difference. iv. Sexual abuse of women and children are crimes and should be addressed separately and urgently. v. Tackling petty corruption is likely to require a commitment from government on several fronts and at all levels to : a. Drive forward activities on grand corruption, make prosecutions more robust, and publicise successful cases to strengthen t he message that corruption is unacceptable; b. strengthen local government structures, enhance sanctions for corruption, and work closely with civil society to raise citizens’ awareness of anti - corruption policies currently in place ; c. continu e to inform the public about their rights in refusing to pay bribes; 71 Need reference for final version of Baseline Survey – title and source 72 Cit i zen’s Agenda for Prosperity (CAP ) Coalition in Critical Perspectives Of Governance ; op.cit.

10. amounted to about 0.1 per cent (29 out of 3011) of all bribes , 64 but interestingly nearly half of these (14) were in the health sector. This is an area that could be further explored when more data is available. 2.5. To Pay or not to pay ? When confronted by a situation where a bribe could or should be paid for a service citizens have choi ces as to whether to pay or not , and , if they do pay, whether to report it a fterwards. 2.5.1. Paying a bribe In daily life, most citizens pay bribes when asked largely to lower level public officials . In a recent study of corruption and traffic offences, for example, n early three out of five drivers state d they pay bribes when stopped by police . 65 In situation s where bribes are paid, f ocus group participants said that they were paying ‘daily’ and were divided between ‘paying and reporting’ and ‘paying and going about their normal businesses’. 66 However, the majority stated that they paid and went about their normal business, justifying this by saying ‘ there is not hing else one could do about it at the moment’ . Only in Bonthe, Western Area and Bo have small numbers of baseline survey respondents reported payment of bribes ( at 6.5 per cent, 1.3 per cent and 0.9 per cent respectively ), 67 although focus group participan ts agreed that reporting bribes would be a good way to stop the practice. Afrobarometer surveys indicate that roughly equal numbers of men and women feel that reporting is a waste of time as nothing will be done about it , and that ordinary citizens are po werless to do anything about corruption . This applies to more respondents in Bo (65.5 per cent), Bonthe (58.1 per cent) and Kenema (40.0 per cent) 68 than in other places. 2.5.2. Refusing to pay a bribe Across pilot a nd control groups there are variations in the numbers of respondents who state that the most effective ways to combat corruption are refusing to pay bribes and reporting corruption when it happens . For example, 28.6 percent of people in Koinadugu state that refusing to pay is an effective way to stop corruption, compared with only 6.5 per cent of people in Bonthe 69 . Similarly, 25 per cent of respondents in Koinadugu agreed that people should report corruption when it happens compared with only 6.4 per cent in Kenema. 70 Koinadugu could be an interesting c ase study and might benefit from further follow up. Focus group participants agreed that refusing to pay and/or reporting bribes would help reduce bribery in the longer term but stated that they rarely refuse as they need the services, often urgently in the case of health. The y noted that the consequences of refusing to pay bribes can be delays or blockages in receiving services, falling into constant trouble with the police, being prosecuted or hassled constantly for small offences, and being 64 Monthly Data Analysis for PNB Repor ting Platform October and November Reports. (Assume these will be available online? Please provide reference) 65 Cit izen’s Agenda f or Prosperity (CAP ) Coalition in Critical Perspectives Of Governance , op. cit, 66 Need reference for final version of Baseline Survey – title and source 67 Ibid 68 Need reference for final version of Baseline Survey – title and source 69 Baseline annex 5?, need reference 70 Ibid

3. viii. Citizens ’ confidence in being able to tackle bribery themselves is important when identifying entry po in ts for addressing corruption. Across Africa, peoples’ levels of confidence vary widely by country, but Sierra Leonean citizens f eel the least empowered of all: only 32 per cent agree that they can make a difference, compared with 72 per cent in Botswana 18 . 2. Detail 2.1. Why Bribery? Corruption is a global challenge, 19 but there are marked differences within and between within countries i n the extent to which corruption is tolerated in everyday life 20 . Researchers disagree about the extent to which bribery becomes internalised within the social norms of any society : 21 some studies provide evidence of a link between social norms that tolerat e corruption and the prevalence of corruption, but other studies demonstrate that the correlation is not clear, or that factors such as weak governance may be stronger determinants of corrupt behaviour. 22 What is agreed, however, is that c orruption persists because it becomes a system, and at local level it can provide benefits for some people in places where the state does not. 23 Below we examine the different facets of bribery in Sierra Leone as it affects the daily lives of lives of citizens. 2.1.1. Causes of b ribery in Sierra Leone : governance T here are deep - seated structural influences in Sierra Leonean society that foster and maintain bribery and corrupt practices; these influences are resilient and persistent, and are an intrinsic part of socio - economic rela tionships and transactions in all spheres of society. 24 The impact of this is that corruption and bribery is perceived to be embedded in public and private sectors as well as in NGOs in Sierra Leone . 25 Studies highlight citizens’ negative views of their gove rnment and of government efforts to tackle corruption , 26 with 85.9 per cent of respondents in one survey stating that some, most or all government officials were involved in corruption. 27 O nly religious institutions are perceived to be less corrupt than othe r bodies with nearly 61 per cent of citizens having moderate or high levels of confidence in them, compared with 10.9 per cent for the traffic police 28 . Specific elements of weak governance that undermine effective functioning of service delivery are iden tified as ‘poverty, greed, low levels of remuneration, lack of integrity, weak fiscal management regimes, breakdown of discipline and the rule of law, and lack of 18 ‘People and Corruption: Africa Survey 2015’ Transparency International (TI) and Afrobarometer 19 See, for example ‘People and Corruption: Europe and Central Asia’ T ransparency I nternational 2016 20 op. cit. 21 See the U4 Anti - Corruption Resource Centre: http://www.u4.no/publications/literature - review - on - social - norms - and - corruption 22 Ibid 23 See, for example, ‘ Why can’t Greece shake its corruption problem ’ ? Boston Globe August 2014 24 Coffey; ‘Anti - Corruption Commission Political Economy Analysis’ December 2016 25 For example: National Corruption Perception Survey 2013 produced by the Centre for Development and Security Analysis (CEDSA); and Afrobarometer op. cit. 26 Afrobarometer Survey Round 6; http://afrobarometer.org/online - data - analysis/analyse - online 27 Ibid 28 National Corruption Perception Survey 2013 produced by the Centre for Dev elopment and Security Analysis (CEDSA)

2. presents an unacceptable burden for people who are already struggling to afford necessities like putting food on the table or accessing medical care ” . 7 iv. Poor governance and corruption thus perpetuate poverty and inhibit common good economics and foreign investments which would benefit the creation of sustainable development . v. Sierra Leone is not the only country affected by bribery but fares poorly in global indexes : The Global Corruption Barometer 2015 8 places Sierra Leone at number 119 out of 168 countries with a score of 29 9 , which is one of the worst in Africa . Sierra Leoneans, along with their neighbours in Nigeria, Liberia and Ghana, are the most negative about levels of corruption: on average over half the people in these countries think that their public - sect or institutions are affected by high levels of corruption and their governments are failing to tackle it. 10 A cross Africa the likelihood of having to pay a bribe to a public official varies significantly by country: the regional average is 22 per cent , but the likelihood in Sierra Leone is almost twice as high wi t h 41 per cent of citizens claiming to have paid a bribe in the last 12 months. 11 vi. Citizens understanding of bribery is critical to the analysis. Sierra Leoneans interviewed for the PNB Baseline Su rvey 12 displayed a clear understanding of bribery as it relates to corruption. 13 Participants in Focus Group Discussions (FGDs) stated that they were aware that bribery is part of corruption and that it is both unacceptable and wrong. These findings apply b oth to citizens who pay bribes and the public officials who accept them. vii. In terms of trends , many people in countries across Africa, including Sierra Leone, think that corruption levels are rising 14 . Afrobarometer conclusions for Sierra Leone specifically indicate that over 70 per cent of respondents think corruption had ‘increased a lot’, or ‘increased somewhat’. 15 By contrast, in Mali only 31 per cent of citizens stated that corruption had increased , and half thought it had reduced. 16 T he perceived mismana gement of additional funds provided to the government for the Ebola response in Sierra Leone may have contributed to the perception that bribery was worsening or becoming more widespread, 17 although Ebola fund mismanagement is more linked to grand rather th an petty corruption. 7 Ibid 8 TI and AB ‘People and Corruption: Africa Surve y 2015’ op.cit. 9 On the TI scale, countries are considered to have corruption under control if they score 50 or above. 10 ‘People and Corruption: Africa Survey 2015’ Transparency International (TI) and Afrobarometer 11 ‘People and Corruption: Africa Survey 2015’ Transparency International (TI) and Afrobarometer 12 The baseline survey used quantitative and qualitative methods to collect data through i) a literature review; ii) a household survey/questionnaire on perceptions of corruption; iii) key informant in terviews with service providers , community authorities, heads of public institutions etc.; iv) Focus Group Discussions with diverse groups of citizens in all districts ; and v) district analysis of related questions in the Afrobarometer Round 6 data - set. 13 Pay No Bribe, Sierra Leone: Household Baseline Survey and Analysis of Afrobarometer Data. September 2016; www.pnb.gov.sl 14 ‘People and Corruption: Africa Survey 2015’ Transparency International (TI) and Afrobarometer 15 Afrobarometer Survey Round 6; http://afrobarometer.org/online - data - analysis/analyse - online 16 ‘People and Corruption: Africa Survey 2015’ Transparency International (TI) and Afrobaro meter 17 See the Audit Service of Sierra Leone reports 2014 and 2015 http://www.auditservice.gov.sl/report/assl - report - on - ebola - funds - management - may - oc t - 2014.pdf

6. 2.3.1. Corruption in Education More than 50 per cent of families in the six districts surveyed for the PNB baseline survey paid a bribe to enrol a child in a state school. Interestingl y, the analysis ranked Bombali as the highest among pilot districts , with 63.6 per cent of respondents reporting that they had paid a bribe for school placement, compared with 39.0 per cent in Western Area . Overall , however, citizens in control districts ( Bonthe and Koinadugu) paid more in placement costs across both districts (64.4 per cent ) than any of the pilot districts. 41 The higher numbers of bribes paid in the control districts of could be associated with a lower availability of schools , and /or perhap s lower awareness of the fact that school enrolment should be free . Since September, citizens’ reporting of bribery indicates that 18 per cent of all bribes reported are concerned with education, behind health ( 22 per cent) and police ( 48 per cent) , and e ducation is one of only two sectors where more women than men have submitted reports. Most education reports highlighted payments made for obtaining grades and exams. 42 2.3.2. Corruption in Health In their daily lives, most Sierra Leoneans encounter health servic es at some point, and l arge numbers of them pay for health facilities. Baseline survey analysis indicators that 36.6 per cent of people pa id bribes for health services on average in pilot districts, but that this varies significantly between Bombali where 57.0 percent of respondents had paid bribes and Western Area where only 15 percent had paid. The highest rate of bribe payers for education in pilot districts was also recorded in Bombali. However, overall the two control districts accounted for the highes t percentages of respondents that had paid extra costs, averaging 67.2 percent: almost twice as high as the average across pilot districts . 43 Numbers of men and women were roughly similar in both cases. Citizen reporting of bribery since September places he alth at 22 percent of all reports , with under five child health being the most frequently cited service. About six times more women than men have submitted reports on health since September , which is probably because the services in question are those with which women are more involved. 44 2.3.3. Corruption in Water For water and sanitation, the PNB baseline survey focused on extra payments to water companies, government or service provider officials to obtain water in pilot districts: control districts have almost no access to piped water. Findings indicate that 19.8% of respondents in pilot districts paid extra (i.e. higher than the published charges) to get water. District analysis indicates Kenema and Bombali districts account for higher percentages of bribe - pay ing respondents at 28.2% and 21.1%, respectively. 45 C itizens’ report s on payment of bribes to water represent only 1.5% of total payments since September, but this may be because the ACC is targeting the water sector in one of its public education campaigns . Over one third of water sector reports r eferred to paying a bribe for new connection s in Kenema district. 46 About twice as many men as women have made reports about water. 41 Need reference for final version of baseline – title and source 42 Monthly Data Analysis for PNB Reporting Platform October and November Reports. (Assume these will be available online?) 43 Ibid 44 Ibid 45 Ibid 46 Monthly Data Analysis for PNB Reporting Platform October and November Reports. (Ass ume these will be available online?)

1. A Behavioural A nalysis of Bribery in Sierra Leone Corruption: the abuse of entrusted power for private gain 1 This document was compiled as part of the ‘Pay No Bribe’ (PNB) programme of support to the Anti - Corruption Commission of Sierra Leone, funded b y UKAID. The overall objective the programme is to enable the Sierra Leone Anti - Corruption Commission (ACC) to design, manag e and implement a system for real - time reporting of corruption by the users of services. The system target s the points of service de livery that are routinely prone to bribery and where demands for bribes impact heavily on the poorest and most vulnerable, including the grow ing numbers of urban poor. These are:  Health: User fees for basic services under the Free Healthcare Initiative  Ed ucation: User fees in primary education  WASH: Connection fees  NPA: Connection fees  Police: Carrying out of police duties Programme activities began initially in 4 pilot districts: Bo, Makeni, Kenema, Western Rural and Western Urban. A Baseline Survey cov ered these districts plus two control districts: Bonthe and Koinadugu , which were selected to reflect opinions in parts of the country that differed from those of districts around Sierra Leone’s four principle cities: Makeni, Bo, Kenema and Freetown. Citiz ens’ reporting of bribes since implementation began has provided additional data about patterns and trends, but this data is not statistically robust . 1. Introduction /Overview i. Bribery is part of corruption , and is understood as o ffering, giving or receivin g something of value with the purpose of influencing the actions of an official in the discharge of his or her duties. 2 Tackling bribery and corruption is a challenge in Sierra Leone , where o fficial audit reports have recorded about 1.4 trillion Leones (a pproximately US$260m) leakages of state funds over the last ten years of managing government budgets. 3 ii. Focusing on the five sectors outlined above , t his report examines how bribery and corruption affect the lives of citizens in Sierra Leone , and how citi zens’ and officials’ values and attitudes towards corruption affect behaviour in situations where bribery occurs . Petty bribery/ corruption , with which this report is largely concerned, usually involves the exchange of small amounts of money or minor favour s to obtain service s and/or preferential tr eatment . I t exists within and forms part of the social and economic framework of society . Grand corruption pervades the highest levels and systems of a national Government, leading to a broad erosion of confidence in good governance, the rule of law and economic stability. 4 iii. Studie s on corruption have shown that poor governance, typically manifested through corruption is “a major deterrent to investment and economic growth and has had a disproportionate impact on t he poor.” 5 Some indicate that the poorest are almost twice as likely to pay a bribe than more affluent groups , 6 and they are also more likely to go without services when they do not have the resources to pay. In this sense “public sector graft 1 The definition most commonly used by DFID www.transparency.org/what - is - corruption 2 Based on the definition in the Legal Dictionary: www.legal - dictionary.thefreedictionary .com/bribery 3 ‘Corruption Stops with Us: Ending bribery for traffic offences in Sierra Leone’, Citizen’s Agenda For Prosperity (CAP) Coalition in Critical Perspectives Of Governance, Volume 6, Jan 2016 4 UN Anti - Corruption Toolkit, UNEP; http://www.unep.org/training/programmes/Instructor 5 Marco Tavanti; The Cultural Dimensions Of Corruption: Integrating Cultures In The Teaching Of Anti‐Corruption In Public Service Teaching Anti - Corruption: Developing Foundation for Business Dignity , (Principles of Responsible Management Education Book Seri es), Business Expert Collection Press, 2013 6 ‘People and Corruption: Africa Survey 2015’ Transparency International (TI) and Afrobarometer TI and AB ‘People and Corruption: Africa Survey 2015’ op.cit.

8. than those in urban areas (33.8 per cent), while i n the contro l districts, 67.6 per cent of respondents in rural areas and 60.0 per cent in urban areas had paid extra. Water and police sectors are sector s where urban costs appear to be higher than rural costs. For water in pilot districts only, 23.8 per cent of urb an respondents and 15.8 per cent of ru ral respondents paid extra for water. For police, a nalysing payment amounts by urban/rural residence revealed 30.5% of respondents in urban areas and 21.7% of those in rural areas had paid police in pilot districts , an d 17.3 per cent in control areas . 2.3.7. Corruption compared: gender There is little evidence to date of major differences in the targeting of men or women in relation to payment of bribes or in the amounts that they pay. In daily life, it is the citizens tryi ng to access a specific service who pay, and they are more likely to be men in the case of police and drivers/traffic offences and possibly more likely to be women in the case of health and education facilities. Women and possibly children may be targeted for sexual abuse in some sectors (see 2.4.2 below) , which requires further investigation. 2.4. What constitutes a brib e ? Participants in f ocus group discussion s held as part of the PNB Baseline survey stated that bribes are ‘favours’ which are usually paid in cash and/or in the form of food and livestock. In the case of women, sexual favo urs may be asked for and given, but c ases of men being asked to provide sexual favours were not specifically mentione d . 2.4.1. Cash bribes I nformation reported through the PNB Bas eline Survey and programme reporting 51 and other sources demonstrates that cash is the preferred form of payment for bribe s: between 93 per cent and 96 per cent of bribes were paid this way o ver the first two months of PNB . The amounts paid vary by sector a nd by location , but on average most people pay less than SLL 50,000 52 in the five PNB sectors . Higher bribes (over SLL 500,000 53 ) were reported to have been paid in 15 cases across all PNB sectors except water, with an additional 15 cases occurring in the ‘ Other’ category , 54 outside of the PNB sectors. The services covered by these categories are presumably able to extract higher value bribes . 55 Of the PNB pilot sectors, e ducation has the highest average value of reported bribes, 56 and these are equally dist ributed across the five services within the sector . 57 The relative ly large amounts normally paid in bribes may contribute to the worryingly high prevalence of sexual f avours recorded for this sector , as some pupils may not be able afford cash payments ( see paragr aph 2.3 .2 below) . In all sectors , ther e are signi fi cant differences between districts in 51 Monthly Data Analysis for PNB Reporting Platform October and November Reports. (Assume these will be available online?) Please provide reference, also for Baseline Survey 52 Approximately £7.00 at December 2016 exchange rates 53 Ap proximately £71.00 at December 2016 exchange rates 54 Such as the judiciary, road safety authority, NRA, national registrations secretariat, port authority, etc. 55 Afrobarometer/TI perceptions data indicates that Sierra Leone has the highest bribery rate in Africa for services through the courts; ‘People and Corruption: Africa Survey 2015’ Transparency International (TI) and Afrobarometer 56 Monthly Data Analysis for PNB Reporting Platform, October and November Consolidated Reports 57 Admissions, Fees, Grades and Exams, Other and Report Cards