2024

ANTI-CORRUPTION COMMISSION OF SIERRA LEONE

An independent institution established for the prevention, investigation, prosecution and punishment of corruption, corrupt practices and to provide for other related matters. 

Contact us on: +23278832131 or info@anticorruption.gov.sl
Address:  Integrity House, Tower Hill, Freetown Sierra Leone, West Africa.

REVIEW REPORT - COMPLIANCE MANUAL ADOPTION IN BO AND KENEMA DCs

System & Processes

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1. 1 REPORT ON THE FURTHER FACIL IT ATION OF THE C OMPLIANCE MANAGEMENT AND SANCTIONS ENFORCEMENT HANDB OO K FOR SYSTEMS AND POLICY REVIEW RCOMMNDATION IN BO AND KENEMA DISTRICTS NOVEMBER, 2022

10. 7 Part 3.1 Availability of the Legal Provisions Part 3.2 Commitment of Compliance Delivery Champions - MDAs

11. 8 Part 3.3 Commitment of Compliance Delivery Champions - ACC Part 3.4 Commitment of Compliance Delivery Champions - CSOs

12. 9 Part 3.5 Compliance Risks Part 3.6 Key Partnership for Compliance

13. 10 Part 4: The 4 Compliance Management Tools Part 4.1 Compliance Result Plan Matrix

9. 6 Part 3: Improving Compliance The presentation was however purely focused on part 3 and part 4

14. 11 Part 4.2 Data Capture and Reporting Template Part 4.3 The Compliance Barometer Matrix (CBM)

16. 13 7.0 CONCLUSION Owing to the above, the training was a success as it has enhanced participants understanding of the provisions of the ACC Compliance Manual with specific focus on Compliance Enhancement Mechanisms and Tools that will facilitate improvement incompliance with ACC Systems and Policy review recommendation within MDAs in the provinces.

4. 1 1.0 BACKGROUND/INTRODUCTION For more than a decade, the Anti - corruption commission (ACC) has been grappling with the challenge of enforcing full compliance to the implementation of its systems and policy review recommendations despite the provisions enshrined in section (8) of the Anti - corruption commission a ct 2008 as amended in 2019. Since then, the administrative and operational activities of over forty (40) high corruption risk ministries, Department and Agencies (MDA) have been reviewed with over 1,500 recommendations proffered, that will help minimize the occurrence of corruption, corrupt practices and promote services delivery . The implementation of the said recommendations has been followed up by the M onitoring and C ompliance Unit of the ACC to ensure compliance in line with Section 8 of the Anti - Corru ption Act, 2008 as amended in 2019 . H owever, results from such monitoring 0ver the years have been very unsatisfactorily. Most of the MDAs roved around no compliance (0% - 40%) . One of the critical challenges iden tified was lack of a clear guideline on the management of the compliance and procedure and enforcement. That necessitated the call for a compliance management and enforcement procedure handbook. A consultant was hired in early 2020, funded by OSIWA and de veloped a handbook titled “ C ompliance Management and Sanctions enforcement Procedure Handbook for systems and policy Review Recommendations “The process of developing this handbook was highly participatory and consultative. Inputs were made from different stakeholders that included MDAs NGOs, civil society organizations and ACC staff in the western areas as well as in the provinces.

8. 5 3.0 METHODOLOGY Letters of participation were sent to Thirty (30) randomly selected MDAs in Bo and Kenema each. A properly and adequately prepared PowerPoint focused on guiding MDAs in ensuring full compliance with ACC Systems and Policy Review Recommendations was separately presented to participant in Bo and Kenema. The presentations were don in the ACC conference halls in Bo and Kenema. There were question a nd answer sessions after each presentation. The soft copies of the Compliance Management and Sanctions Enforcement Handbook for System and Policy Review Recommendations and the Facilitation PowerPoint were shared with participants present 4.0 OUTCOME OF THE FACILITATION: In his opening statements in both facilitations (P resentations ) , t he Director of P revention D epartment Rashid B arbar Turay informed participants that that compliance with ACC recommendations by MDAs in the provinces have been very low since the introduction of the Compliance Manual. He said the facilitation was meant to further popularize the compliance manual as a way to impr ove the compliance levels of MDAs in the regional offices from No Compliance to Full Compliance . The Head o f M onitoring and C ompliance Unit Ibrahim Sorie Kamara - kay did the Power Point presentation . He painstakingly explain ed the content of the compliance manual. He under scored the importance of MDAs complying with ACC Systems and Poly Review Recommendations to which he said “is an effective to eradicate or suppress corruption and improve service delivery i n public sector and in the in the provinces specifically . He specifically provided guidance to MDAs as to how to ensure full compliance. Below were some of the key areas that were presented t o facilitate MDAs in the provinces to achieve full compliance.

15. 12 Part 4.4 MDA Compliance Reporting Template 5.0 SUCCESSES i. The trainings were successfully conducted in all two districts. ii. MDAs’ representatives were able to discuss the provisions of the Compliance Manual and made relevant references. iii. The training created the platform for MDAs in the provinces to enhance their compliance with ACC Systems and Policy review recommendations. iv. Participants were able to identify additional Comp liance enhance mechanisms and tools. 6.0 CHALLENGE The facilitation could only cover two 2 districts 9 Bo and Kenema). There is need to replicate same to the other 10 districts in the provinces.

7. 4 Sanctions enforcement Procedure Handbook for systems and policy Review Recommendations , to MDAs in BO and Kenema districts to further guide them in ensuring full compliance with ACC systems and policy review recommendation which is the ultimate objective the compliance manual. 2.0 OBJECTIVE The broad er aim of the further popularization of the compliance handbook was to improve and subsequently ensure full compliance with ACC S ystems and policy Review Recommendations in the regional offices of the MDAs. The sub objectives were: To discuss and enhance participants understanding of the provisions of the ACC Compliance Manual To facilitate improvement in compliance with ACC Systems and Policy review recommendation within MDAs in the provinces. To Guide participants from MDAs on the specific actions to be taken by them as contained in the Compliance Handbook to ensure full compliance with ACC Systems and Policy Review Recommendations/. To remind participants from MDAs of the Four main compliance sanctions that can be taken by the ACC based on Compliance Level. To remind participants of their obligation to ensure full compliance with ACC Systems and Processes Review Recommendations. To suppress corruption and improve service delivery within MDAs in the province To clarify the doubts participants from MDAs had about the compliance manual that had resulted in low levels of compliance. To share the soft copy of the compliance handbook with MDAs representatives to ensure they have it as a working document to promote compliance with ACC recommendations.

5. 2 The said handb ook was finalized, printed, and presented to MDAs and other stakeholders in the western and provinces in 2021. The Compliance Management and Sanctions enforcement Procedure Handbook for systems and policy Review Recommendations has brought about improvemen t in the compliance levels of MDAs especially in the Western area, with most MDAs now falling within S ignificant Compliance (80% - 89%) and F ull C ompliance (90% - 100%) . For instance, in the Western Area, the following MDAs have achieved F ull C ompliance (90% - 100%) . with ACC Systems and Policy Review Recommendations: The Sierra Leone Correctional Service 96%, The Ministry of Works and Public Assets 100 % The Sierra Leone Immigration Department 93% The Sierra Leone Road Transport Corporation 92% The Sierr a Leone National Water Resources Management Agency 95% The Sierra Leone National Fire Force 90% T he following MDAs in the Wester n Area have Achieved Significant Compliance (80% - 89% ). The Ministry of Social Welfare 86% Free Town City Council 81% GUMA Valley Water Company 89% Except for the Local Councils whose Compliance have been on average Significant (80 % - 89%) based on Six ( 6) Local Councils, whose compliance was monitored in December 2021, the compliance level of MDAs in the regional offices (provinces) remain ed low with all of them still roving around Moderate compliance (50% 79%) and No Compliance (0% - 50%) .

6. 3 F or instance, though the Ministry of Basic and Senior Secondary Education achieved a Moderate Compliance of 56% in the Western Area , but all the Six (6) Ministry’ s regional offices sampled achieved No Compliance as follow: The Bo District Office 36% Kambia District Office 46% Bombali District Office 46% Kenema District Office 27% Kono District Office 46% Pujehun District Office 36 % Again, though the Ministry of Social Welfare achieved a Significant Compliance of 86% in the Western Area, but the Seven (7) Ministry’ s regional offices sampled achieved on average a Moderate Compliance (50 % - 79 %) as follows: Kono District Office 46 % - No Compliance Kambia District Office 48% - No Compliance Bombali District Office 67% - Moderate Compliance Port Loko District Office 50% - Moderate Compliance Moyamba District Office 58% - Moderate Compliance Bo District Office 57% - Moderat e Compliance Kenema District Office 63% - Moderate Compliance From the above data it was obvious that there was higherlevel of Compliance with ACC Systems and Policy Review Recommendations in the Western Area than in the provinces. It was against th at background that the Monitoring and C ompliance U nit of the P revention Department of the ACC with funding from the Open Society Initiative of West Africa ( OSIWA) undertook a two day start - off further facilitation (sanitization workshop) of the ACC Compliance Management and

3. 1 TABLE OF CONTENTS 1.0 BACKGROUND/INTRODUCTION .............................................................................. 1 2.0 OBJECTIVE ................................................................................................................... 4 3.0 METHODOLOGY ........................................................................................................... 5 4.0 OUTCOME OF THE FACILITATION: .......................................................................... 5 Part 3: Improving Compliance ................................ ................................ .................. 6 Part 3.1 Availability of the Legal Provisions ................................ ....................... 7 Part 3.2 Commitment of Compliance Delivery Champions - MDAs .................. 7 Part 3.3 Commitment of Compliance Delivery Champions - ACC ..................... 8 Part 3.4 Commitment of Compliance Delivery Champions - CSOs ................... 8 Part 3.5 Compliance Risks ................................ ................................ .................... 9 Part 3.6 Key Partnership for Compliance ................................ ............................ 9 Part 4: The 4 Compliance Management Tools ................................ ....................... 10 Part 4.1 Compliance Result Plan Matrix ................................ ............................ 10 Part 4.2 Data Capture and Reporting Template ................................ ............... 11 Part 4.3 The Compliance Barometer Matrix (CBM) ................................ .......... 11 Part 4.4 MDA Compliance Reporting Template ................................ ................ 12 5.0 SUCCESSES ................................................................................................................... 12 6.0 CHALLENGE .................................................................................................................. 12 7.0 CONCLUSION ............................................................................................................... 13

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