2. 1

14. - 13 - Had it not been for those 4 i napplicable recommendations, NWRMA would have achieved a compliance score of 95% , by fully implementing 20 out of 21 applicable recommendation s and for which NWRMA would have been celebrated in line with Section 4.3 of the CSEPH for Systems and Processes Review Recommendations. The only applicable recommendation that was not complied with by NWRMA had to do with the Internal Auditor ( IA) . He still did not conduct audits . He did not present reports on a quarterly basis on the operations or activities of the Agency. The last audit conduct ed and reported on by the I nternal A uditor was in 2020. Failing to conduct an internal audit has the risk of the Agency being unable on a timely basis to identify and correct deviations from standards, policies, procedures, laws, regulations, and best practices that may lead to corruption.

22. - 21 - corruption. This is the only applicable recommendation that was not complied with by NWRMA . 8 .0 CONCLUSION In line with Section 4.3 of the CMSEPH for Systems and Policy Review Recommendations, the Management of the NWRMA should be commended for fully implement ing 20 of the 2 1 applicable recommendations proffered by the ACC ’s S ystems and Processes Review, representing a 95 % compliance score. This was a clear indication that, the M anagement of NWRMA took the instruction s of the C ommission seriously and that it was p oised towards improving

8. - 7 - 1.0 INTRODUCTION/BACKGROUND In line with Section 8 (1) of the ACA , 2008 as amended in 2019, the Monitoring and Compliance Unit (M&CU) of the Corruption Prevention Department (CPD) of the ACC have completed a detailed monitoring for compliance with Systems and Processes R eview recommendations SPRR at the NWRMA to track and gauge the compliance level of the Agency with ACC Initiatives to ensure an effective, efficient, economic and equitable service delivery by the A gency. The System s and Processes of the NWRMA were reviewed by ACC in 2021 and the report l unched in the first qua rter of 2022 to which Twenty - five ( 25 ) corruption prone weaknesses were identified in Nine (9) thematic areas . T he same number of recommendations were proffered in a view to reverse those processes and strengthen those weakness es . The NWRMA was e stablished by an Act of Parliament in 2017 with the mandate to regulate, utilize, protect, develop, conserve, control and generally manage water resources throughout Sierra Leone. The Agency is responsible to ensure that the water resources of the country are controlled in a sustainable manner. T he review was part of a holistic review of the Systems and Practices of the Water Sector in Sierra Leone which includ ed the Sierra Lone Water Company (SALWACO ) , Guma Valley Water Company (GUMA), the Ministry of Water Resources (MoWR) and the National Water Resources Management Agencies ( NWRMA ) . The review focused on Budgetary Allocation and Utilization by these A gencies and ministr ies in the W ater S ector and separate reports were prepared and launched . Thus, this monitoring report also only focused on gauging the compliance level of NWRMA with the 12 recommendations proffered to her by the ACC R eview T eam. The idea of monitoring for compliance (Gauging the Compliance Levels of Ministries, Department s and Agencies (MDA) ) with ACC recommendations is consistent with the saying by Peter Drucker “ W hat get measured gets managed ” (Drucker,1954) . Monitoring for compliance also provides assurance to the ACC and

23. - 22 - transparency , accountability and suppressing corruption in the executi on of its duties. 9.0 RECOMMENDATIONS We recommend: That a letter of commendation be written to the Management of NWRMA for fully implementing 20 (95%) of the 21 applicable ACC ’s Systems and processes R eview recommendations. That the Management of NWRMA through the Audit Committee engage s the Directorate of Internal Audit at the M oF to ensure the assigned Internal Auditor carry out quarterly internal audit s at the A gency and report on same. That the 4 impracticable recommendations highlighted in Tab le 1 above be cancelled by the ACC in line with section 8(3) of the ACC Act,2008 as amended in 2019. Going forward, all MDAs especially the Ministry of Finance that have a stake and primary responsibility in the implementations of some recommendations proffered to MDAs, be invited to the presentation of Systems and Processes Review reports.

12. - 11 - letter addressed to the Commission in line with Section 8(2) of the ACA , 2008 as amended in 2019, which states: “ Where a public body considers that the changes in practices and procedures as contained in the instructions would be impracticable or otherwise disadvantageous to the effective discharge of its duties, the public body shall make a representation to the Commission in writing w ithin seven days of receipt of the instructions ” Table 1 below shows the 4 impracticable recommendations and the barriers that prevent ed their implementation. Figure 3 : The Compliance Score of NWRMA including the 4 inapplicable recommendations

4. 3 TABLE OF FIGURES Figure 1 : The ACC Compliance Barometer (CB) .......................................... . - . 8 - Error! Bookmark not defined. Figure 2 : The ACC Compliance Rate Calculation ....................................... .. . - 9 - Figure 3 : The Compliance Score of NWRMA including the 4 I napplicable R ecommendations .......................................... ........................... - 10 - Figure 4 : The Compliance Score of NWRMA excluding the 4 I napplicable R ecommendations ...................................................................... - 14 -

9. - 8 - the public in general about the achievement of the objectives and benefits of systems and processes reviews in MDAs through the gauging of compliance with ACC instructions. 2.0 OBJECTIVES The overall aim of this monitoring exercise was to measure the compliance level of the NWRMA with the ACC ’s SPRR . To achieve th at aim, the key objectives were . To measure the compliance leve l of NWRMA with the 25 ACC ’s Systems and Processes R eview recommendations. To provide the ACC with insight on the effective utilization of public resources at NWRMA. To Identify any barriers/ issues, preventing and/or stalling the implementation of the SPRRs for possible corrective intervention To produce and present a report on the find ings (compliance Level) and proffer recommendations for the ACC to take further actions considering the relevant sections of the CMSEHSPRR. 3.0 SCOPE & METHODOLOGY T he M onitoring exercise focused on the implantation of the twenty - five (25) recommendations proffered by the S ystems and P rocesses R eview Teams . A correspondence in respect of an inception meeting was sent to and held with the M anagement of NWRMA to ensure a common understand ing the objectives, processes, and expected outcome of the monitoring exercise. Key I nformants (KI) were interviewed, and documents examined to triangulate with oral explanations provided that related to the implementation of the recommendations.

17. - 16 - Plan. This ha d the strength of preventing any drift , because staff who implement ed activities and who also kn e w the problems or barriers, faced in implementing activities , were given the opportunity to set aside resources to overcome challenges while implementing their core functions. The Agency had established a functional and effective Finance and Budget Committee with representatives from Senior Management and Middle level M anagers. This Committee now frequently met and discusse d financial and budget ary matters relating to the A gency’s operations. This provid e d the A gency the strength to identify and correct on a timely basis, any financial and budget ary deviations that may ris e to corruption. NWRMA now had a designated Budget Officer (BO) . Though the BO was assigned to four A gencies namely , NWRMA, National Commission for Democracy (NCD) , Small and Medium Enterprises Agency (SMEA) and th e Electricity and Water Regulatory Commission (EWRC) , she h a d her work station at the NWRMA because NWRMA ha d more operations than the other three. This BO now provide d technical support in the preparation of the A gency’s budget and ensure d that all activities funded and implemented were consisted with the A gency’s budget and S trategic P lan. NWRMA now revised it budget and activities in line with allocations received . This approach of budget flexing allow ed the A gency to prioriti z e its activities and prevent corruption. 7.3 Variance in Government Allocation and A pproved Budget 1 (33%) ou t of the 3 recommendations proffered in respect of the variance in the government allocation and approved budget indicator ha s been fully implemented. In line with the ACC ’s Systems and Process Review recommendations SPRR NWRMA now align ed all its activities with its Strategic P lan. Prior to the ACC Systems and Process Review ( SPR) in 2021 the A gency did not prepare a budget on its own. Its budget was subsumed into the national budget in a single line by the M oF . For 2022, the Agency prepared i t s budget in line with its

16. - 15 - Table 2 above shows the detailed analysis of the compliance status of NWRMA. Below is an analysis of the Agency’s compliance based of thematic areas 7.1 Strategic Plan The 2 (100%) recommendations proffered in respect of Strategic Plan have been fully implemented i n line with the ACC SPRR , A workshop was held at the Occasion Resort in Bo with all the Directors and Managers of the various Directorates, D e p ar tments and Units of the Agency in which the S trategic P lan of the A gency was discussed as a way of popularizing it . This mean t every staff was now aware and focused on contributing towards the achievement of the strategic goals of the Agency in the next three years. This focused awareness has the strength of promoting an effective and efficient use of resources that may suppress corruption within the Agency. NWRMA now aligned all its activities with its Strategic P lan. Prior to the ACC ’s Systems and Process Review in 2021 the A gency d id not prepare a budget on its own. Its budget was usually subsumed into the national budget in a single lin e by the MoF . For 2022, the Agency prepared its budget in line with its S trategic P lan and all activities undertaken in 2022 were consistent with the A gency’s S trategic P lan. Such alignment has the strength of keeping the A gency attentive towards realizing its strategic goals of regulating , utilizing, protecting, developing, conserving, controlling and generally managing water resources throughout Sierra Leone. Whilst preventing waste of resources and corruption. 7.2 Budget Preparation The 4 (100%) of the recommendations proffered towards the budget preparation indicator have been fully implemented i n line with the ACC SPRR , The budgetary process in the Agency was now participatory, in that all the Directorates, D epartment s and Units now ma d e inputs in the preparation of the A gency’s annual budget in line with their activity plans, informed by the Strategic

7. 6 The idea of Monitoring for Compliance is consistent with the saying by Peter Drucker that “What get measured gets managed”. Monitoring for compliance provides assurance to the ACC and the public in general about the achievement of the objectives and benefits of systems and policies reviews in MDAs by gauging and reporting on the compliance scores of MDA with ACC Systems and Policies reviews recommendations . WHY MONITORING FOR C OMPLIANCE? A letter of commendation be written to the Management of NWRMA for fully implementing 20 (95%) of the 21 applicable ACC ’s Systems and P rocesses R eview recommendations SPRR . That the Management of NWRMA through the Audit Committee engage the Directorate of IA at the Ministry of Finance (MoF ) ) to ensure the y assigned an Internal Auditor that would carry out a quarterly internal audit at the A gency and report on same. That the 4 impracticable recommendations highlighted in Table 1 be cancelled by the ACC in line with section 8(3) of the ACA 2008 as amended in 201 9 . Going forward, all MDAs especially the Ministry of Finance that have a stake and primary responsibility in the implementation of some recommendations proffered to MDAs, be invited to the presen tation of Systems and Processes Review Reports.

19. - 18 - Water use and Catchment fees from the Water us e and Catchment Regulation, 2021. These regulations are currently being popularized for the public to gain awareness and knowledge of the mandate, roles and citizens ’ responsibility on water management and the environm ent in a bid to facilitate and strengthen revenue generation. 7 .5 Donor Funds 1 (50%) of the 2 recommendations proffered on the revenue generation indicator , had been fully implemented i n line with the ACC SPRR , All donor funds received were now aligned with the Agency’s budget and S trategic P lan. The financial support received from donors was always directed towards a specific aspect of the Agency’s S trategic P lan to complement GoSL allocation that was always deficit. Two case s in hand were: In 2020 Le5.2 billion was budgeted, Le2.7 billion was approved, but only Le0.9 billion was received. In the same year the United Nation Development Program (UNDP) supported the Agency towards the popularization of her Strategic Plan which was then used to complement government allocation towards the communication of the Agency’s S trategic P lan. I n 202 2, the Agency budgeted for the construction of 300 Water Columns b ut only received allocation for 10 Water Columns. In the same year the Catholic Relief Service (CRS) provided Five Hundred Million Old Leones (Le 500,000,000 ) to the A gency for the construction of Water Columns to complement the allocation received from G oSL. All of these were in line with the A gency’s 2020 - 2021 S trategic P lan .

21. - 20 - control reviews, as work must now move from the Director of Finance to the Finance Assistant through the Finance Office r and Vise - Vasa. This was not possible when there was only one staff member in the Finance Unit. A ll bank reconciliations are now reviewed by the Finance Office r after be ing prepared by the Finance Assistant and approved by Finance Director. This has the strength of identifying and correcting on a timely basis any bank reconciliation error that may lea d to corruption. The outstanding un - credited bank reconciliation issues totaling Le13,475,700.00 (Old Sierra Leone Leone s ) has now been corrected by the BSL) . These were two separate payments of Le11,302,000 to SV Electronics and Le 2, 1 73,500 to Africell that were credited in the A gency’s cashbook, but not debited i n the Agency ’s Bank Account at the B SL , though the payment s were made by the bank. This has now been corrected by BSL. 7.7 Internal Audit 2 (67%) of the 3 recommendations relating to Internal Au dit have been fully implemented i n line with the ACC ’s ( SPRR ) Though there had not been a resident IA , but there are now two (2) IA assigned to the Water Sector including NWRMA by the MoF . An Audit Co mmittee has now been established by NWRMA, though there were no Audit Report s to discuss. However, the Audit C ommittee now me t o n a quarterly basis to discuss external audit reports and matters of risk relating to the operations of the Agency.  The IA s were still not conducting audits and presenting reports on a quarterly basis on the operations or activities of the Agency. The last audit conducted and reported on by the I nternal A uditor was in 2020. This ha d the risk of the A gency being unable to identify on a timely basis and correct deviations from standards, policies, procedures, laws, regulations, and best practices that may lead to

6. 5 EXECUTIVE SUMMARY To gauge the compliance of the National Water Resources Management Agency (NWRMA ) with the ACC ’s A nti - Corruption Commission (ACC) Systems and Processes Review Recommendations (SPRR) in line with Section 8(1) of the ACC A ct, 2008 as a mended in 2019, the Monitoring and Com pliance Unit of the Prevention Department of the ACC undertook this exercise to assess the Agency’s compliance level. Data analyzed showed that NWRMA within three (3) months of receipt of the ACC ’s Systems and Processes Review recommendations SPRR, achieve d 80% Compliance Score, by fully implementing 20 out of the 25 recommendations proffered to the Agency. Such a compliance score according to the Compliance Management and Sanctions E nforcement Procedure Handbook for Systems and Policy Review Recommendations (CMSEHSPRR) is termed as Significant Compliance , which mean t NWRMA should be further engaged by the ACC to ensure full compliance with the remaining 5 recommendations. It is however worth noting that 4 of the 5 outstanding recommendations cannot be applied or achieved by NWRMA because they were out of the control of the Agency. These impracticable recommendations were highlighted in a letter addressed to the Commission in line with Section 8(2) of the A nti - Corru ption Act (ACA) , 2008 as amended in 2019 . Had it not been for the 4 inapplicable recommendations, NWRMA would have achieved a compliance score of 95% by fully implementing 20 out of 21 applicable recommendations and for which NWRMA should have been celebrated in line with Section 4.3 of the CMSEPH. The only applicable recommendation that was not complied with by NWRMA had to do with the Internal Audit (IA) . He d id not ) still conduct Internal A udits . He does not present reports on a quarterly basis on the operations or activities of the Agency. The last audit conducted and reported on by the I nternal Auditor was in 2020. Failing to conduct an internal audit has the risk of the A gency being unable on a timely basis to identify and correct deviations from standards, policies, procedures, laws, regulations, and best practices that may lead to corruption. We recommend that.

1. 0 MONITORING FOR COMPLIANCE WITH SYSTEMS AND PROCESS ESS REVIEW RCOMMENDATIONS AT THE NATIONAL WATER RSOURCES MANAGEM E NT AGENCY ( NWRMA) PREPARED BY: CORRUPTION PREVENTION DEPARTMENT MONITORING AND COMPLIANCE UNIT - ACC SEPTEMBER 2022 The Anti - Corruption Act,2008

11. - 10 - 5.0 THE COMPLIANCE RATE (SCORE) The Compliance Score (CS) of the Agency is calculated as: 6.0 SUMMARY OF COMPLIANCE Data analyzed showed that NWRMA within three (3) months of receipt of ACC ’s Systems and Processes Review recommendations ( SPRR ) achieved 80% Compliance Score, by fully implementing 20 out of the 25 recommendations proffered to the Agency. Such a compliance score according to the CMSEPH was termed as Significant Compliance , which mean t NWRMA should be further engaged by the ACC to ensure full compliance with the remaining 5 recommendations. It was however worth noting that 4 of the 5 outstanding recommendations, indicated below, cannot be applied, or achieved by NWRMA, because they were out of th e control of the A gency. These impracticable recommendations were highlighted in a Compliance Score = Number of Recommendations Fully Implanted Total Number of Recommendations Proffered 100 Figure 2 : The ACC Compliance Rate Calculation

20. - 19 -  In the case of budgeting for donor support , NWRMA could not directly budget for this. D onors only communicate d their interest of supporting an Agency during the year after going through the Agency’s S trategic P lan that was normally shared with them and after the budget would have been prepared . The financial support received from donors was always directed towards a specific aspect of the Agency’s S trategic P lan to complement the GoSL allocation that was always in deficit 7 .6 Financial Management NWRMA had fully implemented five 5 (100%) of the recommendation s proffered towards the Financial Management Indicator i n line with the ACC ’s SPRR , All financial records (documents) were now properly filed and labeled based on their activi ties and sources of finance. This has created a clear and ease of trail of financial transactions that may now act as a deterrent for corruption. During the ACC ’s Systems and Processes review, there was only one staff in the Finance Unit (Finance Officer) . The F inance D epartment has now been strengthened by: First transforming it into a D irectorate, headed by a director that is a Chartered Accountant with long standing experience in the A ccountancy Profession. There are two staff that now supports the D irector of F inance. A Finance Office r and a Finance Assistant. All the 3 staff in the Finance Directorate have been provided with appropriate workstation s , a computer each and a network printer. They are also usually provided with motor vehicle s to facilitate their movement to and from the MoF and the Bank of Sierra Leon e (BSL) when arises. As there are now three (3) staff within the Finance Directorate, there is now clear segregation of duties in the finance function. This has the strength of identifying errors and any potential fr aud on a timely basis through quality

18. - 17 - S trategic P lan and all activities undertaken in 2022 were consistent with the A gency’s S trategic Plan.  As indicated in Table 1 above, the A gency could not comply/implement 2 (67%) of the 3 recommendations proffered on this indicator, because of the reasons advanced. Please See Table 1 (Summary of Findings) section above for more details on this. 7.4 Revenue Generation 2 (100%) of the recommendations proffered on the revenue generation indica tor have been fully implemented i n line with the ACC ’s Systems and SPR NWRMA has now clearly identified and defined it revenue streams which are the GoSL Allocation and Donor support. In respect of the GoSL allocation, the A gency has now defined the following as the main sources of revenue and now prepares its budget in that direction. Mining Companies Application Fees. This is a one of f revenue streams . Administrative Fees License fees. A nnual revenue Direct allocation from GoSL And in a bid to strengthen her revenue generation in line with the Systems and Processes Review recommendation, NWRMA had facilitated and achieved the enactment of 4 regulations . These regulations have given the Agency the mandate to collect revenue from t he following sources: Dam Safety fees/fines from the NWRMA Dam Safety Regulation 2021 Pollution fines from the NWRMA Pollution Control Regulation 2021 Water dugout and Packeting fees from the NWRMA Water dugout and Packeting Regulation, 2021 and

33. - 32 - INTERNAL AUDIT Recommendations Indicator Import ance Baseline situation/ Challenges ACC’S Target Means of verification (MOVs) Current Progress Measure Responsible Department/Officer 23 Management of NWRMA should go through the necessary procedure to ensuring that a resident Internal Auditor is assigned. Assigned a resident Internal Auditor H The review team observed that the agency does not have any resident internal auditor. Internal Auditor assigned to the Ministry of Water Resources was requested for by the Agency, to conduct a holistic Audit on the Agency’ Financial Operations for the year ending 31 st December 2019 and fir st quarter of 2020. One Internal Auditor Verify Appointment Letter, Attendance register 100% There are now 2 internal auditors attached to the agency. T he Internal Auditors of the Ministry of Water Resource also provi de Internal Audit role to the agency. support to the Agency. 24 Internal Audits must be conducted quarterly to ensure accountability of Government resources Conduct quarterly Audit H No Quarterly audit conducted in the Agency as prescribe by Law Quarterly Audit Verify quarterly audit Report 45% The Interna l A u d it ors assigned to agency are still not conducting quarterly internal audit to the agency. 25 The Management of the Agency should ensure that there is an established Audit Committee Established functional Audit Committee There is no Internal Audit Committee in the Agency Established Audit Committee Verify Audit Committee Minute of Meetings 100% There is an Internal Audit Committee, but never met to discuss on internal audit report s ince there were no report from the assigned auditor from the Ministry. However, the C ommittee meet to discuss on external audit report and other matters of risk relation to the operations of the agency.

5. 4 LIST OF ACRONYMS Anti - Corruption Act ...................................................... ............... ACA Anti - Corruption Commission ........................................................... ACC Bank of Sierra Leone .....................................................................BSL Budget Officer .............................................................................. BO Catholic Relief Service ................................................................... CRS Compliance Progress Assessment Matrix ..........................................CPAM Corruption Prevention Department ...................................................CPD Electricity and Water Regulatory Commission ..................................... EWRC Government of Sierra Leone ..................................................................GoSL Internal Audit ................................................................................IA Key Informants ............................................................................KI Millennium Challenge Coordinating Unit ............................................ MCCU Ministries, Departments and Agencies ....................................... ....... MDA s Ministry of Finance ....................................................................... MoF Monitoring and Compliance Unit .................................................... M&CU National Commission for Democracy ............................................... NCD National Water Resources Management Agency ............................... NWRMA Sierra Lone Water Company ......................................................... SALWACO1 Small and Medium Enterprises Agency ............................................ SMEA Systems and Process Review ........................................................ SPR Systems and Processes Review Recommendations ........................... SPRR United Nation Development Program .............................................. UNDP

10. - 9 - Data on the imp lementation or otherwise of the 25 recommendations were collected and recorded into the ACC Compliance Progress Assessment Matrix (CPAM) . Ratings on the implementation or otherwise of each of the recommendations was mostly participatory and based on verified evidence to facilitate O bjectivity. An exit meeting was held with th e focal p erson who agreed with the preliminary compliance score of the A gency, which was not different from the fina l score. The Draft report was also emailed to the focal person for the input of the Agency’s M anagement before the report was finalized. This process serv ed as validation of the report prior to finalization , p rinting and launching. 4.0 COMPLIANCE BAROMETER In line with Section 3.4 of the SPRR , the following compliance Barometer was used to gauge the compliance level of the NWRMA in a scale of 0% to 100% . Please note the color code and the associated score brackets. 50% - 79% Moderate Compliance (Warning Letter) 0% - 49% No Compliance (Indictment) 90% - 100% Full Compliance Celebrated/Commended 80% - 89% Significant Compliance (Further Engagement) Figure 1 : The ACC Compliance Barrometer

3. 2 TABLE OF CONTENTS EXECUTIVE SUMMARY ........................................................................... .. - 5 - 1.0 I NTRODUCTION/BACKGROUND ......................................................... . - 7 - 2.0 OBJECTIVES ...................................................................................... - 8 - 3.0 SCOPE &METHODOLOGY ................................................................... - 8 - 4.0 COMPLIANCE BAROMETER ............................................................... - 9 - 5.0 THE COMPLIANCE RATE (SCORE) .................................................... .. . - 10 - 6.0 SUMMARY OF COMPLIANCE ................................................................ - 10 - 7.0 DETAILED FINDINGS AND ANALYSIS ................................................... . - 14 - 7 .1 Strategic Plan: .............................................................................. ...... - 15 - 7 .2 Budget Preparation: ........................................................................ ..... - 15 - 7 .3 Variance in Government Allocation and Approved Budget: ................. ... ...... . - 16 - 7 .4 Revenue Generation: ..................................................................... ...... - 17 - 7 .5 Donor Funds ................................................................................. ... .. - 18 - 7 .6 Financial Management: .................................................................. ...... - 19 - 7 .7 Internal Audit: .............................................................................. ........ - 20 - 8.0 CONCLUSION ................................................................................. ... . - 21 - 9 .0 RECOMMENDATIONS ...................................................................... .. . - 22 - 10 .0 APPENDIX DATA CAPTURE AND REPORT MATRIX FOR NATIONAL ......... WATER . RESOURCES MANAGEMENT AGENCY .......................................... - 23 - LIST OF TABLES Table 1: The 4 Inapplicable Recomm endations .............................................. . - 12 - Table 2: Detailed Compliance Score of NWRMA ............................................. - 14 -

25. - 24 - 2 We recommend that the budget should strictly be aligned to activities geared towards achieving the goals set out in the Strategic Plan. These two pieces must be closely aligned and reviewed both separately and together for the Institution to successfully reach the next level in its growth. Align budget with activities The team observed that NWRMA has a developed 5 - year Strategic Development Plan (2019 - 2023). The Strategic Plan is based on International best practice of International Water Regulatory Management (IWRM) for management of water resources by identifying weak wa ter governance, weak framework for disseminating best practice and lessons in IWRM, challenges, opportunities and treats, internal strengths, and weaknesses of the NWRMA, stake holder identification and management and outlines various interventions to address the challenges. We observe that the budgets are prepared by the Ministry with little or no reference to the Strategic Plan . Aliened budge t with activities Verify Budget and activities in the strategic plan 100 % Budget is now prepared and aligned with activities. The budget and activities are now aligned with the strategic plan. However, in 2019 it was the ministry of Finance that prepare the budget on behalf of the agency

15. - 14 - 7.0 DETAILED FINDINGS AND ANALYSIS Table 2 : Detailed Compliance Score of NWRMA # Thematic Areas # of Recommendations Proffered # of Recommendations Fully Implemented # of Outstanding Recommendation # of Imapplicable Recommendation Compliance Score (%) 1 Strategic Plan 2 2 0 0 100% 2 Budget Preparation 4 4 0 0 100% 3 Variance in Government Allocation and approved Budget 3 1 2 2 33% 4 Delay in Government Allocation 1 0 1 1 0% 5 Revenue Generation 2 2 0 0 100% 6 Donor Fund 2 1 1 1 50% 7 Actual Budget after Disbursement 3 3 0 0 100% 8 Financial Management 5 5 0 0 100% 9 Internal Audit 3 2 1 0 67% Totals 25 20 5 4 80% Figure 4 The Compliance Score of NWRMA excluding the 4 inapplicable recommendations

24. - 23 - 10.0 APPENDIXDATA CAPTURE AND REPORT MATRIX FOR NATIONAL WATER RESOURCES MANAGEMENT AGENCY YEAR OF REVIEW - 2021 PROGRESS ASSESSMENT TOOL& COMPLIANCE BAROMETER Description of Progress No Compliance Moderate Compliance Significant Compliance Full Compliance Score Range (0% - 49% ) (50% - 79% ) (80% - 89% ) (90 - 100 %) Color Code Area of Focus STRATEGIC PLAN Anti - Corruption Objectives Institute transparency and accountability principles in the management of public funds Recommendations Indicator Impor tance Baseline situation/ Challenges ACC’S Target Means of V erification (MOVs) Current Progress Measure Responsible Department/Officer 1 The Ministry should popularize the strategic plan to all departments, in a view that all department identifies its mandate in pursuing the overall mandate of the institution Popularize strategic plan to all departments High There was no Strategic Plan presented to the Review Team. inclusive input of all departments in the strategic plan  Verify approved strategic plan, inputs of all Departments and Units 100 % Strategic plan has now been popularized to all the departments of the Agency . A workshop was held with the representation of all Directors and Managers at Occasion resort. Evidence of attendance and report was verified by the monitoring team.

26. - 25 - BUDGET Recommendations Indicator Impor tance Baseline situation/ Challenges ACC’S Target Means of verification (MOVs) Current Progress Measure Responsible Department/Officer 3 We recommend that the budget process be highly participatory. That is the budgeting process starts at the departmental level and moves up to higher levels. Every department within the institution is required to prepare plans for its proposed activities for the next budget period and estimate the costs it will incur. These individual budgets are combined to create a bigger all - inclusive budget Participatory and inclusive budget process . H igh Budget processes is not participatory but rather limited to the to the executive body Participatory and Inclusive Annual Budget Verify Inputs of Department and Unit budget submitted. 100% The budget processes are now participatory. All l department and units now inputs in the preparation of annual budget. There is a budget committee with from all the directorates, and departments 4 The Agency should immediately constitute a Budget Committee Comprising of all Heads of Departments of the board with the free hand to guide the budget process Establishment of approved budget committee H There is no evidence to show that a Budget Committee exists to guide the budget process Approved and functional Budget Committee Verify List of Budget Committee, updated Minutes of the committee, resolution, and Budget work plan 100% The Agency came into existence at the end of the first quarter o f 2019, when the staffing was not fully constituted and therefore not possible to have a budget committee. However, the monitoring team discovers that there is now a budget committee that is functional. Minutes of meetings were verified by the monitoring t eam.

32. - 31 - 20 Clear roles responsibilities should be specified, and reporting lines and obligations established. Established reporting line protocols The reporting line is blank as he lacks supervision or monitoring by a supervisor. Reporting line established Verify Job responsibilities and reporting line 100% There is now clear roles and responsibility and reporting line as the Finance Assistant report to the finance office and the finance officer to the Director of Finance. 21 Management should ensure that bank reconciliation be reviewed by the appropriate personnel as stated in the manual. Review Bank Reconciliation by the appropriate personnel. Bank reconciliation was not done and reviewed by the appropriate personnel as stated in the manual . The Director of Admin and HR, whom with no financial background has been reviewing the financial matters inclusive of reconciliation. Bank Reconciliation Review by the appropriate personnel. Verify Bank Reconciliation 100% There is an updated Bank Re conciliation for all accounts in the Agency. 22 Management should also ensure that Le1,145,000 Revenue not posted into the cash book & suppliers ’payment Le 13,475,700 not on the bank statement should be audited. % of revenue posted on cash book and suppliers’ payment on bank statement Revenue totaling Le 1,145,000 were not posted into the cashbook and , payments made to suppliers totaling Le13,475,700 were shown in the cash book but not on the bank statement 100% Compliance Verify Cash book and Bank S tatement. 100% The outstanding uncredited bank re conciliation issues totaling Le 13,475,700.00 (Old Sierra Leone Leone) has now been corrected by the Bank of Sierra Leone (BSL). These were two separate payments of Le11,302,000 to SV Electronics and Le2,173,500 to Africell that were credited in the agency’s cashbook, but not debited in Agency Bank Account at the Bank of Sierra Lone, though the payments were made by the bank. This has now been corrected by BSL.

29. - 28 - 12 The Agency should Strengthen its revenue generation drive to relax its over burden reliance on Government support Strengthen the revenue generation drive. H igh No control or strengthen of revenue streams Revenue generation strengthen Verify mechanism in place to strengthen revenue 100% Four Regulations have been enacted in 2021: Pollution Control, Water Development & Protection, Water use and catchment and Dam Safety Regulation s . These regulations have mandated the agency to collect revenue from different other sources. The regulations are being popularized by the agency. Donor Fund Recommendations Indicator Import ance Baseline situation/ Challenges ACC’S Target Means of verification (MOVs) Current Progress Measure Responsible Department/Officer 13 The Agency should ensure that all donor supports are aligned to National Budget to avoid duplication of funding. Aligned donor support with National Budget H The review team identified that NWRMA received donation from Millennium Challenge Coordinating Unit (MCCU) of furniture, Plant and Machinery, office equipment etc. to the tune of one billion, two hundred and si xty seventy million, f our hundred thousand Leones (Le 1,267,400,000) for the setting and running of the agency Aligned donor support with National Budget Verify donor and National Budget. 100% The utilization of Donor Funds is included in the Annual Finan cial Statements of the Agency . Reports relating to the use of donor funds are always submitted to the Ministry of Finance. The uses to which donor funds are put are also always subjected to external audit. The Agency received funding from CRS in 2022 for the construction of Colum’s to the sum of 500,000,000 which is in line with the strategic plan, 2020 & 2021 from UNDP .

30. - 29 - 14 All donor funds should be properly budgeted for and reported on. The Agency should maintain a donor register for accountability and transparency purposes. Established donor register Budget all H Furthermore, NWRMA received funding from United Nations International Children Emergency Fu nd (UNICEF) totaling Leones (Le 119,786,500) These f unds were not aligned to the national budget to ensure that there are no duplications in spending on budget items Budgeted all donor funds and establish register Verify Donor Register funds, Budget 85% It is difficult to budget for donor funds since donors only communicate their interest of supporting the Agency mostly within the year after budgets are prepared. However, donor supports are always in line with the strategic plan . Recommendations Indicator Import ance Baseline situation/ Challenges ACC’S Target Means of verification (MOVs) Current Progress Measure Responsible Department/Officer 15 Management should ensure that all activity plans are in line with the approved budget and strictly adhered to. Activity plan in line with budget and strictly adhered to H The Review Team Observed that the attached activity plan is not in line with the approved budget line items. These activity plans are only made in other to access the fund and not carefully thought through or aligned to the budget. All activity plan in line with approved budget Verify activity plan, and actual budget. 100% All activity plans are in line with approved budget and strictly adhered to 16 Virement should be discouraged and if the need arise it should properly be managed and reported on. Discourage virement in the implementation of activities H In fact, the funds are not expended in line with the activity plan approved by the MoF. Virement of funds from one cost center to another without following due process is widespread. No virement in the implementation of activities Verify budget and activity plan 100% The monitoring team identified that there was no virement, as there was only one line budget, and it was strictly adhered to since 2020 to date.

27. - 26 - 5 The Agency should ensure that there should be a designates budget officer to conduct the activities of the Agency. Assigned Budget officer No budget officer from the Ministry of Finance was specifically assigned to the Institution. The one assigned to the Ministry of Water Resources covers the agency but there was no evidence to show that he has been effectively coordinating the budgetary act ivities of the Agency Assigned One Budget Officer Verify appointment letter or correspondence of designation of Budget office, Job description roles and responsibility. 100% There is now a stationed budget officer that facilitates the budget activities in the Agency. However, the officer oversaw three other institutions such as: Small and Medium - Term Enterprise, NIB and NC D. With all of these, no challenges were reported. 6 Variance in budget funds the budget should be revised, and the activities plan should be in line with revised budget. # of activity implemented in line with revised budget Activity implemented are not in line with revised budget Activity implemented in line with approved budget Verify Plan activity, in line with activity implemented report 100% There activities of the agency were always revised in line with allocation received. Variance in Government Allocation and approved Budget Recommendations Indicator Import ance Baseline situation/ Challenges ACC’S Target Means of V erification (MOVs) Current Progress Measure Responsible Department/Officer 7 MOF should provide adequate funds in line with the budget are provided to the institution. Provide adequate funding to the institution. L NWRMA requested Le 530,360,000 for the financial year 2019. On the contrary, the Ministry of Finance disbursed Le392,810,000 for the financial year 2019 100% approved budget disbursed Verify backlog budget variance payment. 40% This recommendation is beyond the control of Agency ‘s Management. In 2021, the Agency submitted a budget of 5.2 billion Old Leones, 2.7 billion Old Leones was approved, and only 0.9 billion old Leones was allocated to the Agency.

31. - 30 - Actual Budget after Disbursement Recommendations Indicator Baseline situation/ Challenges ACC’S Target Means of verification (MOVs) Current Progress Measure Responsible Department/Officer 17 Management of NWRMA should ensure that an actual activity budget should be prepared in conformity with the actual quarterly disbursement made by Government rather than using the unapproved budget plan. Prepare actual activity budget in line with government quarterly disbursement H no actual budget was prepared to reflect the actual amount of disbursement made by Government for the quarter(s). Actual activity budget in line with government quarterly disbursement  Verify Quarterly Activity Budget in line with Government disbursement. 100% Activity plans are now in line with government disbursement. Financial Management Recommendations Indicator Import ance Baseline situation/ Challenges ACC’S Target Means of verification (MOVs) Current Progress Measure Responsible Department/Officer 18 Management should ensure that files are labeled according to budgeted activities and subsequently, all source documents are filed in their respective folders. All files labeled in line with budgeted activities File all source document in respective folder . It was very difficult for the team to trace source documents from files. This is because of documents being bundled up in different files. Documents are not filed according to budget activities; instead, they are mixed up and filed with other monthly a ctivities. File and labelled all activities in line with budget. File all source document in respective folder Verify Activity Files and folder 100% The team identified that there is a systematic filling system in the Agency, as the financial documents were properly file in accordance with budgeted activities, documented and file in their respective folders. Files were verified by the team. 19 The Unit should be adequately staffed and provided. adequate logistics Increase the number of staff in the finance unit The team realized that the finance unit is understaffed, and it is managed and controlled by a single staff (Finance Officer). Personnel increased in the finance unit Verify recruitment procedure of finance officers, appointment letters. 100 % Two addition staff were recruited in the department, finance officer and Assistant finance officer making a total of three staff including the Director of Finance. Logistics were also provided to the team such as computers, workstation , stationaries, and printers etc.

13. - 12 - Table 1 : The 4 Inapplicable Recommendations No. Baseline Recommendation Barrier preventing the implementation of the recommendation. Area of Focus: Variance in Government Allocation and Approved Budget 1 . NWRMA requested Le 530,360,000 for the fiscal year 2019. On the contrary, the M inistry o f F inance ( M oF ) disbursed Le 392,810,000 for the fiscal year 2019. MoF (MoF) should provide adequate funds in line with the budget to the Agency. Letters were written by the Agency to MoF following up on the difference between the budget and amounts received in 2019 to 2021, but to no avail. The public body with direct responsible in this recommendation was the MoF. Therefore, it cannot be implemented by NWRMA . 2. The MoF does not provide adequate funds in line with budget provided by the institution. The MoF should ensure that adequate funds in line with the budget were provided to the institution. This re commendation seemed to be a duplication of the previous one. Letters were written by the Agency to the MoF following up on the difference between the budget and the allocated amounts received in 2019 to 2021, but to no avail. The public body with direct re sponsible in this recommendation was the MoF. Therefore, it cannot be implemented by NWRMA. Area of Focus: Delay in Government Allocation 3. Delay in the disbursement of funds from the MoF to NWRMA The Government of Sierra Leone (GoSL) through the MoF should ensure that quarterly allocations (actual) ar e disbursed on time . MDA s in Sierra Leone would love to receive its quarterly allocation on time. That was not the case in Sierra Leone. Again, the public body with direct responsible in this recommendation the MoF. Therefore, it cannot be implemented by NWRMA. Area of Focus: Donor Fund 4. The Review Team observed that NWRMA received donation from Millennium Challenge Coordinating Unit MCCU for furniture, plants and machinery, office equipment to the tune of One billion, two hundred and sixty - seven million Leones (L 1,267,400,000) for the setting and running of the Agency. The Agency should ensure that all donor supports were align ed to the National Budget to avoid duplication of funding. This was very difficult and likely impossible to budget for. Because:  NWRMA was not a donor driven Agency. Donor fund was not the main source of revenue for the Agency and was not certain that it will always be received.  Donors only communicated their interest of supporting the Agency during the year after going through the Agency’s Strategic Plan that was shared with them. The financial support received from donors were always directed towards a s pecific aspect of the Agency’s Strategic Plan to complement Government of Sierra Leone (GoSL) allocation that was always deficit.  For example, in 2020 Le 5.2 billion was budgeted, Le 2.7 billion was approved, but o nly Le 0.9 billion was received. In the same year the United Nation Development Program (UNDP)) supported the Agency with the popularization of her Strategic Plan which was then used to complement government allocation towards the communication of the Agency’s Strategic Plan.

28. - 27 - 8 The Ministry of Finance should ensure that adequate funds in line with the budget are provided to the Institution. Provide adequate funds in line with budget The Ministry of Finance does not provide adequate funds in line with the budget provided by the Institution % of budget approved by the MOF Verify B udget approved and provided 40% Also, this recommendation is beyond management decision. Management does not have control over adequacy of funds allocated to the Agency, therefore it remains a challenge 9 In case of any future shortfall in revenue that will require adjustment to the budget and activity plan a documented due process should be followed highlighting request, justification, approval, and report. Follow due process in budget adjustment Due pro cesses are not followed in budget activity plan. Follow due process in budget adjustment Verify activity budget plan adjustment 100% There was an aligned budgeted activity work plan that followed due process and approved. Delay in Government Allocation Recommendations Indicator Import ance Baseline situation/ Challenges ACC’S Target Means of V erification (MOVs) Current Progress Measure Responsible Department/Officer 10 The Government of Sierra Leone (GoSL) through the Ministry of Finance (MOFED) should ensure that quarterly allocations (actual) are disbursed on time. # of quarterly allocation disbursed to NWRMA L Delays in the disbursement of funds from the Ministry of Finance to the Ministry of Water Resources. Quarterly allocation of funds Verif y Actual disbursement of funds as against budget, 40% This is also beyond management control because the management of the agency does not have control as to when funds should be allocated to the agency. Revenue Generation Recommendations Indicator Import ance Baseline situation/ Challenges ACC’S Target Means of V erification (MOVs) Current Progress Measure Responsible Department/Officer 11 The Finance unit of the ministry should provide details of all revenue generated activities of the ministry inclusive of water bowser. # of revenue streams identified in the ministry. H igh During the review, the team realized that NWRMA is a revenue generating institution and for the period und e r review, she has generated (Le 82,424,432.84) from its various revenue streams. Identified all revenue generated accounted for the period under review/monitoring  revenue streams identified  Revenue generated and evidence of payment slips, bank statemen t, records of cash book. 100% The Agency have, administrative fees, License, Government subvention and Donor funds,