KAMPALA PRINCIPLE 4:DPs_SUBP 4.C

KAMPALA PRINCIPLE 4 - TRANSPARENCY AND ACCOUNTABILITY

Development Partners

Sub-principle 4.C

Ensure accountability

 

Why is it important? 

 

Development partners have the responsibility to maintain high standards of accountability in projects with the private sector that are funded by international public resources. They need to systematically ensure that all project partners deliver on the agreed results and address any unintended impacts. This requires mutual accountability among partners. For this, appropriate governance in partnerships and projects is key to establish and follow-up on credible commitments, reducing the risk for public and private partners alike. This may be supported by collaboration agreements or memoranda of understanding. Development partners are also being held accountable for their commitments to partner country governments, private sector partners, as well as citizens and taxpayers at home. Transparency about expectations and information on expenditure and results are key prerequisites for mutual accountability. Many private sector partners lack the capacity and experience to report to public partners and the general public on the public resources used in private sector engagement (PSE) through appropriate channels. Negotiations on contractual accountability requirements are therefore important to ease any tensions, including those created by discrepancies with private partners’ own corporate confidentiality rules. Complementary to this, mechanisms to ensure that project partners and third-party contractors report on agreed actions and results as well as any unintended, negative impacts of their operations should be included in PSE programmes and projects with adequate instruments to enforce such requirements and correct course when needed. At the same time, development partners' compliance rules should be flexible enough to ensure that smaller private partners with limited bandwidth can fulfil conditions and procedures.

Self-reflection questions
Discover Tool
Policy Level Project Level
  • Does your government’s or organisation’s PSE strategy require systematic accountability for PSE projects and programmes, including among all project partners, upward (towards headquarters) and downward (down to local beneficiaries)?
  • Do you have a set of rules establishing minimum requirements around accountability for engagement with private sector actors?
  • Do you support and participate in partner government-driven mutual assessment reviews that involve PSE activities?
  • Do you make PSE information, including evaluation reports, publicly available for accountability towards parliaments and taxpayers? (see Sub-Principle 4.B)
  • Does your government or organisation have an ombudsman office which partners and taxpayers can contact to report infractions? 
  • Have you established accountability mechanisms and transparency requirements for contracted intermediaries for your PSE projects and country programmes?
  • Is your PSE project subject to public oversight, consultation and independent evaluation?
  • Have you established an independent complaint mechanism for your PSE project? 
  • Are there internal whistleblowing procedures in place to expose infringements?
  • Have you ensured that staff engaged in PSE projects have sufficient capacity to support accountability and learning processes?
  • In the event of a project causing considerable harm (environmental, social or governance related), how can it be halted or at least adjusted?

Actions to consider
Discover Tool
Policy Level Project Level
  • Have a clear code of conduct and guidance in place to communicate the ground rules and minimum requirements for partnering with your government or organisation to private sector partners. 
  • Commit to mutual accountability by making credible commitments in collaboration agreements to build trust and reduce the risk of private and public partners alike.
  • Promote “performance assessment frameworks” to assess individual donor performance on commitments in a partner country, which can be a powerful tool to incentivise good behaviour among donor peers.
  • Establish independent complaint or grievance mechanisms that are easy to use and freely accessible to all project partners (including marginalised communities and women). 
  • Work with relevant alternative dispute resolution mechanisms to better respond to specific conflicts, including community-level mechanisms and those provided by non-state actors such as non-governmental organisations.
  • Streamline and systematise accountability reviews and processes as much as possible..
  • Use project-level accountability exercises to inform learning and decision making at policy level (see Sub-principle 4.B).
  • Ensure that civil society organisations, trade unions and other stakeholders on the ground play an impartial role in evaluating and holding PSE projects and partners accountable. 
  • At the project start, ensure that information on complaint mechanisms is in the local languages, provide clear guidance on how to use them and how claims will be assessed (e.g. information on the ombudsman office and policy frameworks). 
  • Map out the internal accountability mechanisms of implementing partners to ensure a coherent view of reporting requirements.
  • Encourage the practice of internal auditing and evaluation procedures. 

Pitfalls to avoid
Discover Tool
Policy Level Project Level

      DONT...

  • Keep accountability and transparency standards at minimal levels to avoid off-putting corporate actors.
  • Put in place cumbersome or overly complex accountability procedures for national governments and local stakeholders, even though they may often not be directly involved in PSE projects.
  • Dominate and crowd the accountability agenda in detriment of the partner’s shared commitment and ownership.

      DONT...

  • Treat learning and accountability among diverse actors in projects homogenously. 
  • Assume partner country governments have adequate capacity to manage and navigate accountability requirements.
  • Neglect CSOs and trade unions when ensuring the accountability of corporate actors, or not enrolling them sufficiently in design and evaluation.

COUNTRY-LEVEL EXAMPLES

The Dutch and German development finance institutions, the FMO and DEG, have established independent complaints mechanisms for their PSE activities. These are comprised of staff from the complaints offices of both institutions, and an independent panel of three members. These mechanisms provide accountability by investigating complaints and determining whether partners have adhered to their policies and standards. By soliciting the engagement of independent experts, these complaints are handled impartially and transparently, and dispute resolution is offered.


See also the International Finance Corporation’s compliance advisor/ombudsman. This is an independent accountability mechanism for individuals and communities that have been negatively impacted by the International Finance Corporation’s PSE activities to file complaints and seek resolution.

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