Analysis and case studies Published: 2023 Developed with support from the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) Water Stewardship initiatives (WSIs) can be a powerful form of collective action to address water security issues and joint water risks in a demand-driven, collaborative way that benefits from funding and capacity not generally available to public or social initiatives. But WSIs are only powerful if they work – and this is not an easy feat when success requires balancing complex power relations and water allocation needs. Trust between stakeholders and trust from the wider community is essential for effective, sustainable WSI programming. Integrity is a crucial ingredient to build this trust and address critical yet overlooked integrity risks that can otherwise undermine WSI work and erode credibility. Download (pdf, EN):

By Marcela Lopez, Founder Contested Urban Waterscapes Fighting against corruption is important to water integrity. However, the corruption focus can fall short in explaining why the urban poor continue to be excluded from affordable and adequate water supply services. By drawing upon case study research conducted in Medellín, Colombia, this brief investigates how water integrity is perceived and experienced by low-income users in their daily attempt to secure access to water. It will be argued that promoting integrity, besides controlling corruption, needs to include user perspectives on accountability, participation, and transparency. Moreover, water utilities should better guide users on what is required of them as clients. Such an approach can help water companies create programs that are more responsive to the needs of the urban poor. Download as PDF: Public engagement to improve water services in Medellin (pdf, EN) Introduction Water services in Medellín, Colombia’s second-largest city, are supplied by Empresas Públicas de Medellín (EPM, Public Enterprises of Medellín), a multi-utility company owned by the Municipality of Medellín to which it pays 30 per cent of its utility revenues. EPM provides water and sewerage, natural gas, electricity, telecommunication services, and solid waste collection to over four million people in the metropolitan area. The company has been praised both nationally and internationally for its economic efficiency, quality of services, and low levels of corruption, and as a model to emulate in other Latin American countries (BID, 2012). Over the last two decades, EPM has been increasingly operating like a private company by adopting a competitive and market-oriented logic, with an institutional form of state entrepreneurial behaviour known as corporatization (McDonald, 2014). Paradoxically, while EPM registered US$ 6.9 billion in total revenues in 2013 (Arias Jiménez, 2014) and reported 99 per cent water coverage (EPM, 2011), official statistics estimate that the same year 36,560 households were disconnected from the water services for non-payment of bills (EPM, 2013), representing approximately 5 per cent of the city’s total households. [1] Disconnection for non-payment in Medellín has been interpreted as a problem rooted in widespread poverty (EPM, 2013; Nuñez, et al., 2011). While this aspect is important, it fails to capture the ways in which current water policies systematically exclude low-income households from water access. This study disrupts this narrative by exposing the main difficulties faced by low-income households seeking to secure access to affordable and adequate water supply services. It addresses profound questions: Why are low-income households unable to pay their bills? Which difficulties do they face to be reconnected legally? Why do they connect illegally despite the risk of strict sanctions being imposed by the water company? This approach analyses water integrity from the perspective of low-income users and draws lessons from their everyday struggle to secure access to water. Disconnection for non-payment The reasons for non-payment are multiple and complex. Although economic factors are important, this study illustrates how disconnection for non-payment goes beyond the inability to pay. This analysis is based on a survey conducted with 64 households in 16 different neighbourhoods in Medellín that reported high rates of disconnection from September to November 2011. This information was supported by other sources of published data, including municipal statistics, reports, and in-depth interviews with members of the water company. Results show that disconnection for non-payment is mainly attributed to the following economic and non-economic factors: Unaffordable water tariffs The most common reason for non-payment of bills is the inability to pay. Considering that 68 per cent of EPM’s users are currently registered in the lowest socio-economic strata (Strata 1, 2, and 3) [2] (EPM, 2013), it was not surprising that the lack of affordable tariffs automatically resulted in growing levels of non-payment, particularly in low-income areas as illustrated by Figure 1. From the 64 households surveyed, 71 per cent affirmed that they did not have enough economic resources to afford their bills. Some 77 per cent of the surveyed households reported living on less than a minimum wage salary (US$ 288 per month) and a fluctuating income resulting largely from employment in the informal sector. These problems were compounded by extremely low levels of education and literacy (e.g., 73 per cent reached only the primary school level). The majority of the surveyed households experienced not only disconnection from water, but also electricity, gas, and telephone services. Additionally, unaffordable water tariffs forced households to cut back on other key basics, such as food, clothing, education, health care, and transportation, often to the detriment of family members. Studies have documented that households located in low-income areas spend more than 30 per cent of their income on basic public services (Contraloría General de Medellín, 2003). According to the World Bank, household expenditures on basic public services above 5 per cent of monthly household income are considered unaffordable for the poor (Komives, et al., 2005). Inflexible and complex payments EPM has established diverse programs to help disconnected households pay off a portion of their debts in order to restore service. Although these programs are being designed to fit the different abilities of low-income users, they leave many low-income residents feeling helpless against their accumulated debts and simultaneously due monthly bills. The majority of survey respondents stated that they have approached EPM to arrange payments on their previous bills. However, despite the motivation to pay, they express that their actual economic conditions make paying off their debts simply unaffordable. The findings in the survey also illustrate that a large proportion of households are unable to properly communicate with local authorities and employees of EPM. This is due to the inability to understand the criteria used to calculate bills. The billing system implemented by the company has proved to be too complex for users to understand (Rojas, 2012). Many survey respondents reported having literacy skills too low to interpret monthly consumption as well as poor debt management skills. These factors have led to numerous misunderstandings and significant mistrust between users and the company. According to the survey, many of the households also claim that there is a lack of transparency on how tariffs are established. Seventy-five per cent of households presume that the company is charging more than it should or is charging for a service that is not being provided. In 2015, in order to overcome these communication barriers, EPM launched a new format that presents bill information contained in a way that is visually attractive (see Figure 2). Although exceeding the scope of this paper, a comprehensive study is required to evaluate the impact of the new billing format. Ignorance of legal mechanisms In 2010, the United Nations General Assembly adopted a resolution on the right to water and sanitation (A/Res/64/292), acknowledging that the right is legally binding and calling upon nation-states and international organisations to provide safe, clean, accessible, and affordable drinking water and sanitation for all. [3] This international instrument represents an important basis for the Colombian Constitutional Court to derive the right to water. Although Colombian national law grants water companies the power to disconnect a household for non-payment of services [4], the Constitutional Court prohibits any service provider from disconnecting a household when it is inhabited by individuals under special constitutional protection. [5] Low-income users are provided with officially sanctioned mechanisms such as acciones de tutela (tutelary actions) to hold the state and the water company accountable. This mechanism allows low-income users to directly petition any judge in the country for protection against violations of fundamental rights. For example, in 2010 Ms Adriana Borja filed a tutelary action with the assistance of a local NGO, three months after being disconnected for non-payment. In the claim, Ms Borja stated that she was unemployed and that her husband was unable to work due to an accident. She was also responsible for her unemployed daughter and her two-year-old granddaughter. She requested service reconnection and expressed willingness to enter into an agreement with the company in order to pay her debts, in keeping with her financial capacity. In her case, a judge found a violation of the constitutional right to water as follows: Water disconnection undermines the fundamental right to health and human dignity of the applicant and her family. The lack of adequate water services in her home might produce personal difficulties, which could trigger the deterioration of health conditions in the entire family. [6] An interim injunction was issued on 5 October 2010, ordering the water company to immediately restore the service. This case, however, represents one of the few successful examples where, via tutelary actions, a disconnected household holds the company accountable. However, as the results of the survey show, the extent to which rights are realized depends on the level of access to legal advice and representation, which is minimal in the case of low-income users. Analysis of household survey data also indicates that involvement in decision-making is very limited. The majority of the respondents replied that there is little community organization and poor participation to address their concerns about water disconnection. Many were not aware of the existence of legal mechanisms that guarantee the right to water. Seventy-nine per cent of respondents also expressed that high levels of debt leave them with culpability and shame, even if they are able to reclaim their rights. As one respondent from the barrio Buenos Aires expressed: “Queda muy duro no pagar y encima ir a exigir derechos” (it is hard to not pay and additionally demand rights). The increasing levels of anxiety and feelings of guilt among disconnected households might be interpreted not only as concern about losing access to water but also as fear of being categorized by the water company as “bad” and “undesirable” customers. Informal and illegal connections In the absence of affordable tariffs, many users turn to different informal and illegal practices to reconnect, regardless of the strict sanctions imposed by the water company. During the first seven months of disconnection, EPM installs a trickle valve to suspend the flow of water into the house until debts are paid. In response, family members, friends, and neighbours act in solidarity to secure access to water. This includes giving buckets of water without any costs, sharing facilities such as kitchens and toilets, and reusing water (e.g., flushing toilets or cleaning floors with used laundry water). Other informal arrangements include sharing bills between households or charging per bucket of water. These solidarity practices clearly illustrate that among many users in the first phase of disconnection, the intention to secure access through illegal practices is minimal. Moreover, there is a strong desire to formally reconnect to the water service. When a user accumulates more than seven months of non-payment of bills, EPM cuts off water services. These activities are undertaken by contractors, who are often employed on a temporary basis and are unaware of the legal implications involved in water disconnection. When a house is cut off, there is not much negotiation from the user’s side to halt disconnection, as many express feelings of shame for not having the means to pay their bills. It is in cases such as these that users turn to illegal connections to secure water services for their homes. EPM, in return, severely punishes illegal practices by proceeding with strict sanctions, which in some cases can lead to eviction. Paying for illegal connections makes disconnected users more prone to complex networks of manipulation and extortion. These practices become flourishing businesses after massive disconnections are undertaken. Some respondents of the survey disclosed that local plumbers are hired to remove trickle valves or to build a new service pipe connection from the house to the water main for up to US$10. Additionally, many users admitted that securing access to water is becoming increasingly connected to the complex world of criminalized bands (e.g., paramilitary groups) operating in many neighbourhoods in Medellín. In some cases, these groups become the ultimate authority on who has access and who is excluded, who pays for it and who does not. Lessons learnt and recommendations Understanding water integrity from the perspective of low-income users reveals why still billions of people are not able to obtain safe water supplies, despite technical and managerial efforts. This is particularly important for many Latin American cities, where water inequalities are not being reduced, despite substantial improvements in water and sanitation infrastructure when compared to other cities in sub-Saharan Africa and Asia (Sponk, et al., 2012; Satterthwaite et al., 2015) and active implementation of constitutional changes to support the ‘right to water’ (Harris and Roa-García, 2013). Looking at the complex realities behind the everyday practices of low-income users could inform progressive ways to promote good water integrity, based on principles of accountability, participation, and transparency that take into account aspects such as equity and affordability in service delivery. Promoting transparency A crucial aspect of transparency is access to billing system information. Inaccurate information about the criteria used to determine tariff structures often leads low-income households to misunderstandings, anger, and distrust. It is therefore important to provide users with detailed information about how to interpret and manage monthly consumption, as well as establish diverse communication channels and consultation mechanisms to inform them of their duties (e.g., payment of bills, debts, and sanctions) and their rights (e.g., access to water and related legal mechanisms). Another important aspect of transparency is the role that contractors play in the disconnection process. Contractors are often employed on a temporary basis and are therefore often unaware of the legal implications of water disconnection. Water providers should provide training to contractors not only on consumer’s duties but also on rights. Disconnected households have the right to be informed before their house is going to be disconnected and to learn about the legal mechanisms available to prevent it. Having good legal information could also limit the interference of for-profit actors (e.g., local plumbers, paramilitary groups) in water supply provision and reduce the costs and time involved in carrying out disconnections and reconnections. Providing access to sufficient and understandable information - not only in terms of duties but also rights - is crucial to secure better transparency. It is important that low-income users have accurate information on how their tariffs, debts, and sanctions are structured in order to strengthen their capacity to hold the water company accountable. If water providers work with intermediaries, they need to be trained to offer users the expected level of information and transparency in their operations. Promoting accountability The right to water represents a powerful instrument to hold government and water companies accountable. However, how can enforceability be ensured? Many national governments have recognized the right to water in their constitutions and have established judicial mechanisms to protect this right when it is violated. Although legal measures are important to realisation of the right to water, these measures alone do not guarantee that there will be fair implementation. If the goal is to achieve equitable access to water, it is important that low-income users understand what the right to water means and how existing legislation can be enforced. Strengthening local organizations (e.g., NGOs, ombudsmen) that work to protect the right to water is necessary to provide low-income users with legal assistance and advice. Recognizing the right to water signals that states and water companies can be held accountable, enabling low-income users to access water regardless of their capacity to pay. However, low-income users need to be informed about what the right to water means and what kind of legal mechanisms are available to secure its realization. Promoting participation To defend the interests of low-income users, it is necessary to promote spaces for participation where they can be involved in decision-making processes and work closely with water companies. In cases of disconnection for non-payment, programs to pay debts tend to constitute the primary mechanism of information. As disconnected households fail to pay their bills while simultaneously paying off their debts, the absence of communication with the water company becomes a prevailing practice. This entails serious problems, as disconnected households tend to resort to illegal practices to restore water services. According to an interview conducted with a staff member of EPM, after disconnected households turn to illegal reconnections, it is difficult for water companies to bring them back into the formal water system. This experience shows that, in many cases, this mechanism is one-way only. Few cases can be found of users that shift from illegal connections back to regular service. Besides payment programs, water companies should create opportunities for participation, taking inputs from low-income households into consideration and promoting exchange with other interested groups. In Venezuela, for example, the Mesas Técnicas de Agua (MTAs, Grassroots Technical Water Committees) promote exchange between representatives of the civil society, local government, and the water company (Chavéz, 2012). So do the water forums in South Africa, where issues about the payment of bills are raised (Smith, 2005). However, to ensure genuine participation, low-income users must not be treated simply as passive subjects that need to be ‘informed’ about what happens when bills are not paid on time; instead, they might be recognized as active players capable of raising concerns, claiming rights, and discussing service-related issues. Conclusion The ethical use of public services is the responsibility of every urban dweller. However, compliance with this duty becomes harder when the dialogue between users and providers is minimized and the documentation related to said services is not sufficiently clear. Analysing integrity from the perspective of low-income users provides an innovative approach to understanding the problem of a lack of access to water, beyond economic determinism. Aspects such as complexity in bill formats, inflexible payment programs, little information on legal mechanisms to reclaim the right to water, as well as low communication skills and participation are also barriers that preclude low-income users from the full enjoyment of adequate water services. The right to water must be upheld, and it should not be denied to anyone because of inability to pay. In particular, low-income users must be supported to develop their capacity to protect and claim this right and enjoy access to water in line with their own capacities. Understanding everyday struggles to secure access to water is key to creating policies and programs that are more responsive to the realities of the urban poor. Therefore, water companies must closely cooperate with low-income users in order to understand their competing priorities (e.g., food, education, health) and create multiple payment programs and water tariffs in order to guarantee affordable and accessible water services. About the author: Marcela López completed her doctorate in geography at the Freie Universität Berlin, looking at the conflicts around access to water in Medellín. She is the founder of the platform Contested Urban Waterscapes, which explores water inequalities in urban contexts from an interdisciplinary perspective. For more information on the platform, see contestedurbanwaterscapes.net. Acknowledgements: Editorial review by Tammi L. Coles, Binayak Das, and Jacopo Gamba, WIN. PDF print design by Philip Kieckbusch, diehingucker.de. Footnotes, bibliography, and credits Download full brief for complete bibliography [1] According to the 2014 Medellín census (Medellín Cómo Vamos) the city reports a total of 775,683 households. Thus 36,560 households disconnected for non-payment represent approximately 5 per cent of the city’s total households. This percentage excludes households located in informal settlements where formal infrastructure is notably absent. [2] Socio-economic stratification of households (Strata 1 is the lowest income and Strata 6 is the highest one). [3] For further information see: UN General Assembly, A/Res/64/292, Human right to water and sanitation, [28/07/2010]. [4] Public Services Law 142 of 1994 (Article 140 and Article 141). [5] The Constitutional Court prohibits any service provider from disconnecting a household that is inhabited by children, single mothers, elders, and Internally Displaced People (e.g., see Decision T-546 of 2009, Decision T-717 of 2010, and Decision T-092 of 2011). [6] Municipal Criminal Court decision of Medellín, 2010, translated by the author. For further information see: Republica de Colombia, Rama Judicial de Poder Público, Juzgado Treinta y Dos Penal Municipal, Medellín, “Borja v. Empresas Públicas de Medellín y Municipio de Medellín” [Juez Álvaro Diego Quintero Giraldo, 05/10/2010].

This brief is based on the study “Water Financing for Flood Protection in the Wetland Areas (Haor) in Bangladesh: Determining the Scope for Social Accountability” by Touhidul Hoque Chowdhury. This thesis, for obtaining the degree of Master of Arts in Development Studies from the Institute of Social Studies (ISS), The Hague, was supported by WIN. Sunamganj is a wetland district in the North-Eastern part of Bangladesh, which is flooded every year due to monsoon rain and flood water from the Brahmaputra river. Flooding is a natural henomenon in the country’s wetlands (Haor). To protect local crops from the most severe floods, the government implements crop protection embankment projects through the Bangladesh Water Development Board (BWDB). The study on which this brief is based, reveaed that corruption contributed directly to the failure of protecting local crops during a particularly devastating flood in 2017. The research highlighted how integrity deficits within these projects came to light as a result of a grassroots civil mobilisation, which put pressure on authorities to investigate. Media and community pressure lead to policy change In 2017, newly constructed embankments in Sunamganj collapsed, leading to the flooding of 142 Haors. Damages estimated by the government included crop loss on 371,401 hectares with a value of over USD 800 million (rice and fodder)[1], in addition to losses in fishery and livestock. This led the local NGOs/CSOs and media to report on the damage, linking it to poor maintenance of the flood protection embankments in the wetland areas. Local-level journalists were providing real-time reports through social media and reaching out to the local community as well as the national press. Media reports showed that not only contractors, but also engineers and other officials were involved in corruption in the construction and maintenance of the flood protection structures as well as in other major development projects (river dredging and irrigation). They brought nationwide attention to the losses. The wide coverage on the issue in the national media, prompted the government to review the “Kabita Nitimala 2010”, the policy governing Haor Management, which led to the implementation of the “Kabita Nitimala 2017” policy. In the revised policy, project implementation was shifted away from the BWDB’s responsibilities and delegated to the local administration. The BWDB was made responsible for technical support of the implementation process. Despite this swift policy change, it was revealed that there were many places where the height of the embankments was increased beyond the established design parameters, which became a barrier to the natural flow of floodwater into the wetlands. People’s active participation in the local governance system has always been a challenge in the local development context. The geographical characteristics of the wetland areas make it even more difficult to promote people-centered governance. Because the livelihoods of the Haor community are vulnerable to the natural catastrophes (i.e., floods), the government implements water projects to protect the Haor community and its crops. The “Kabita Nitimala 2017” is one of the policies that created scope for the local people to implement the water projects under the leadership of the local administration. It was brought forth due to the pressure from the media and local organizations on the regulatory bodies, which prompted to launch an investigation into the corruption that occurred in these projects. The role of the media was acknowledged by government officials and NGO activists who were interviewed for the study. Investigations by the anti-corruption commission In response to the tremendous pressure from the media and civil society, the Anti-Corruption Commission (ACC), which is mandated to investigate corruption in any public institution, decided to launch an investigation. During 2017, the ACC found evidence of irregularities in the embankment development and maintenance. Despite the ACC’s efforts in filing lawsuits against the BWDB duty bearers for negligence and malpractice during the implementation of the water projects, the wetlands communities are sceptical as to whether the responsible authorities and other parties involved will be held accountable. Currently, the cases are moving slowly. Conclusion The chronic failure to maintain the crop protection embankments is an integrity issue, affecting the lives and livelihoods of the community members. The policy change altered the local accountability mechanisms, shifting ownership to the local administration and providing more space for local community involvement in a region where geographical characteristics have increased the challenge of promoting people-centered governance. The new mechanisms are promising but still have their obstacles. It was, for example, revealed that since implementation there are many places where the height of the embankments was increased beyond the established design parameters, becoming a barrier to the natural flow of floodwater. It is important that joint accountability mechanisms are encouraged to ensure that BWDB and the local administration are active participants. Media and civil society engagement also remain crucial. They played a significant role in building popular mobilisation, informing policymakers of wrongdoing and holding all stakeholders to account, thus directly contributing to safeguarding the rights of the local population. [1] Haor Advocacy Platform (HAP) Position Report Flash Flood 2017

3.6 BILLION PEOPLE DON'T HAVE SAFE SANITATION SERVICES, IT'S TIME FOR CHANGE. SERVICE PROVIERS CANNOT AFFORD WASTING RESOURCES TO INTEGRITY FAILURES Water and sanitation services mean life and dignity for city residents and are essential to urban development. Poor integrity practices of sanitation and water service providers impact severely on the delivery of these services. They directly raise costs and legal risks, weaken service levels, and threaten operators’ reputation and long-term sustainability. Improving integrity on the other hand can improve service delivery, efficiency, and credit-worthiness. For too long, integrity risks have been underestimated or ignored by water and sanitation service providers because they were too difficult to measure, too misunderstood to fix, or too sensitive to address. However, there are now well-established tools to assess integrity practices and to address integrity risks by strengthening corporate governance, management and compliance. Water and sanitation service providers can now take advantage of these tools to improve and ensure sustainability of service delivery. By taking a practical, positive, and non-confrontational approach focusing on integrity rather than corruption, they can also make a sensitive issue accessible and less taboo. “An action utilities can take is prioritising transparency and accountability in corporate governance. This is what a service provider in Ecuador did with the Integrity Management Toolbox. They looked at risks and found ways to act preventively. They invested in accountability through public consultations, presentations and publications. They also used innovative ways to reach communities, promoting participation through community theatre, adding information on bills, and investing in communication technology.” - Marcello Basani – Lead Water and Sanitation Specialist, Inter-American Development Bank Tools for integrity: understanding and mitigating common integrity risks Getting a good understanding of the critical integrity risks is the first step towards being able to address them. There are a number of tools to help with this process: internal financial or compliance audits can provide useful input on corruption risks, as can data analysis on key risk areas such as procurement. There are also a number of governance indicator frameworks and assessment methodologies that can be used. The international Aquarating utility benchmarking standard has recently launched an additional Focal Analysis to assess corporate integrity. WIN also has simpler complementary tools for integrity assessments in utilities, including an indicator-based Integrity Assessment . Such tools can bring to light integrity red flags and help to identify where risks might materialise: are procurement rules adhered to or more frequently applied with exceptions? Are high level positions exercised by under-qualified people? Are staff accepting bribes within the exercise of their duties? WIN’s assessment tools are generally applied as part of a longer term integrity management change process. InWASH is used to drive a process of identification of priority risks and the tools to mitigate them. It includes an integrity management toolbox with example tools to improve integrity across different areas, such as human resources, customer service, procurement, governance, and financial management. A version of InWASH, the Integrity Management Toolbox has already been used by water and sanitation utilities across the globe serving over 4 million users. Case studies: water operators in Latin America lead with integrity and see results in customer satisfaction Several sanitation and water utilities across Latin America are successfully using integrity assessment and management tools. They shared their experiences at the Stockholm World Water Week 2021 (see full video of their interventions here) . Like many sanitation and water utilities we work with, these leaders are using integrity as a cross-cutting management principle to improve service and build resilience and effectiveness. An integrity change management process like the one they have all initiated, usually starts with an integrity assessment followed by training and awareness raising, internally and for users. Most of these utilities have already seen efficiency gains and are particularly positive about the impact of customer engagement measures and efforts to open service and management data. Water Operator: SEDAPAL Location: Lima, Peru Population served: 11.512. 594 Representative: María del Pilar Acha, General Secretary “With WIN and support from IADB, we worked on mapping integrity risks to mitigate acts of corruption in procurement, clandestine connections, and abuses in water billing. We also created the Office of Regulatory Compliance and Institutional Integrity. Both, paying customers and users who have received free water during the pandemic have access to complaint mechanisms and can provide comments. We’ve made a clear commitment to transparency and included this in our KPIs and monitoring via Aquarating.” Water Operator: CEA Location: Queretaro, Mexico Population served: 1.920.539 Representative: José Luis de la Vega, Head of the Transparency Unit “We see integrity as a way of acting in all administrative and operational processes. We see transparent management, accountability and participation as fundamental elements to mitigate acts of corruption and embezzlement. We put this into practice by creating a results-based budget, implementing institutional internal control, and directly engaging with the public via a portal for communities. The Integrity Management Tool made it easier for us to assess the effectiveness of practices we have been applying such as a code of conduct.” Water Operator: AySA Location: Buenos Aires, Argentina Population served: 14.441.422 Representative: Marcelo Rogora, Director of Integrity and Best Practices “The integrity consortium (WIN, SIWI and cewas) has collaborated with us in identifying risks, monitoring and evaluating them. We developed an online tool (AySA DATA) which has four pillars: integrity and transparency, citizen participation, open data and digital transformation. With it, we seek to incorporate the citizens’ perspective in the management of the company and to adhere to accountability processes. When we refer to integrity risks, we cannot only focus on internal mitigating processes; citizens are essential. They can make complaints, queries, suggestions and thus, serve as sources of risk identification.” Takeaways Overall, building water integrity into the values of an organisation can be transformative. It is a new way to identify and address root causes of recurring issues and to strengthen trust with users and funders. As such, it benefits sanitation and water operators. And, it benefits users, who receive better sanitation and water services, as is their human right. Read about what service providers can do for integrity in WIGO2021

An interview with Bubala Muyovwe of the NGO WASH Forum for '#GovernmentsPay Your Water Bills The #GovernmentsPayYourWaterBills campaign was launched in 2020, backed by WIN, End Water Poverty, SWIM (Solutions for Water Integrity and Management), and the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ). We investigated utilities in 18 countries and found that 95% of respondents reported cases of non-payment of water bills by public institutions, including for water services to public office buildings, or military and police facilities. Overall, the collection rate for public customers is consistently lower than for private customers. And, in at least 10% of cases, the reason for non-payment is linked to abuse of power or undue interference. These late or missing payments by public institutions have direct impact on the ability of utilities to provide service.They hamper the realisation of the human rights to water and sanitation and highlight a lack of accountability. There are ways to address the issue: these require determination and concerted action from stakeholders and public institutions. With these findings in hand, we teamed up with partners in five countries (Ghana, Kenya, Mexico, Nepal, Zambia) to investigate the situation in specific contexts and advocate for change. In Zambia, a local campaign led by the NGO WASH Forum was launched in 2020 and was particularly successful. They organised radio discussions to raise public awareness on the issue and engaged with the Minister of Water Development to discuss sector financing, debt, and outstanding water bills of public institutions. In a positive move for accountability, the Zambian Parliament requested that NGO WASH Forum and partners submit a response to the National Auditor General’s report on commercial water utilities in November 2020. The SWIM team caught up with Bubala Muyovwe, the National Coordinator of the Zambia NGO WASH Forum, for her take on the campaign and next steps. Were you surprised that 95% of utility companies surveyed report non-payment of water bills by public institutions? Bubala Muyovwe: I was not surprised that non-payment was reported. But I did not foresee the magnitude of the situation. I also had little idea about how payments are made or how the debt is managed. In a 2018 budget address, the Honourable Minister of Finance did mention that the ministry were unbundling debt. That’s when I first realised that the government had a history of non-payment. What was the situation in Zambia at the time of your research in terms of government non-payment? Bubala: When we started the research, an audit carried out by the Auditor General revealed that nearly 475 million Kwacha (26 million USD) was outstanding in terms of unpaid bills. This was in line with figures we received from the National Water Supply and Sanitation Council (NWASCO). In 2020 the government reduced some of the debt, also by carrying out debt swaps with other entities, like the electricity company and the tax authority. Was government non-payment previously a topic of discussion within the water sector and/or civil society? Bubala: Honestly, no. I would like to think that a conversation took place between NWASCO, the regulator, and the utility companies. Perhaps they were trying to find strategies for dealing with the situation because it was hindering the operational capacity and efficiency of many utilities. As a civil society group, we didn’t have much experience with these problems. When the Auditor General’s report on the performance of the utility companies came out—just before we signed up for the campaign—it became clear that there were several issues related to the management of utilities, and we began to think about ways to discuss these. Who would you say is most affected by government non-payment in Zambia? Bubala: Ultimately, it is the small community user, the private user. Access is already a challenge, and the government has recently expanded the mandate of the commercial utilities. Previously, coverage by commercial utilities was restricted to urban and peri-urban areas. Their mandate has now increased to include rural areas, where much more of the population lives. To increase and improve access in rural areas and attain the Sustainable Development Goals requires considerable investment. What was your approach for the campaign? Bubala: We first focused on getting information from the key actors. NWASCO was instrumental in helping us understand sector power dynamics. Initially, we also tried to reach out to the commercial utilities. A few were able to provide some information, but overall this approach didn’t yield many positive results and we changed our strategy. We then focused on awareness-raising. We ran some social media campaigns and designed several messages for national television. We wanted to sensitise everybody to the issues, especially in light of the COVID-19 pandemic. The Ministry of Water Development directed commercial utilities not to disconnect water during the pandemic. This added to existing debt, but also created a new dynamic by showing that some users had not been consistently paying their water bills. We therefore came up with a holistic message emphasising everybody’s responsibility to pay for their water use, including government departments, private users, and so on. During the campaign, we were able to meet with the Honourable Minister of Water Development, Sanitation and Environmental Protection, Dr Jonas Chanda, and his technical staff in late 2020. We discussed debt and took the opportunity to emphasise the importance of assisting the commercial utilities by addressing various governance issues. Non-payment of the utilities is turning into a big problem. To have any chance of attaining our national targets, this is something that cannot keep happening. What aspects of the campaign would you say were key to its success? Bubala: Dr Jonas Chanda has since become the Minister of Health, but the meeting with him in late 2020 remains a key success for the campaign as it opened possible paths for collaboration with the health ministry. We’re hoping to follow up to ensure utilities get as much support as possible when debt is dismantled and to find strategies to ensure bills are paid promptly. In late 2020, the NGO WASH Forum also made a joint submission with WaterAid Zambia to the Committee on Parastatals of the National Assembly to discuss the Auditor General’s report on the water companies. The submission highlights how commercial utilities play a critical role in the realisation of the human right to water and sanitation, gives insight on their performance, and provides recommendations on how to improve the efficiency of their operations to ensure value for money. One recommendation is for government to link funding to operational efficiency of utilities, while looking at ways to address financial leakages and enhancing oversight. As a Forum, we also discussed with various members of parliament the operational side and impact on utilities of different political decisions, highlighting the need to ensure utilities have the resources to sustain operational costs over the long term. Did you involve any other stakeholders in the campaign? Bubala: We are a network of national, regional, and international NGOs, and we brought in a number of our members to plan and formulate the various submissions and engagements with government. We tried to be as participatory as possible. Even before the COVID-19 pandemic, some Forum members were already supporting commercial utilities, for example, by providing the necessary water treatment chemicals. They are particularly involved in devising strategies to support utilities. Other members helped share the work with partners and on other platforms. Going forwards, we would like to have a bit more engagement with the public and raise awareness as much as we can. How would you characterize the changes in the sector so far? What are you most optimistic about? Bubala: It’s very significant, being able to have the conversation around accountability where debt is concerned. This is a big win for us. We’ve also become a recognised voice, with the national assembly asking us to contribute to the conversation around this key governance issue. That relationship is something to harness to help effect change. Moving forwards, we hope to see some big improvements and policy changes to strengthen governance in the sector. In terms of leadership, we were sorry to see the Minister of Water Development move to the Ministry of Health but it is valuable that we now have a WASH ambassador in the health sector. We see a great opportunity for him to champion some of our causes. At a recent courtesy meeting, the new Minister of Water Development, Sanitation, and Environmental Protection, the Honourable Raphael Nakachinda, has demonstrated good leadership and a willingness to collaborate with the Forum. We see potential to collaborate with the government and continue to strengthen the sector. Thank you Bubala for your insight on the campaign and all the best going forward! Bubala Muyovwe is a health psychologist, soon-to-be lawyer, and a human rights activist. She is the National Coordinator of the Zambia NGO WASH Forum. She has worked for 10 years in the water and sanitation sector in Zambia to influence policy and practice through advocacy. SWIM (Solutions for Water Integrity and Management) is an NGO based in Dresden, Germany, working for a world in which every person has unconditional, conflict-free access to water and sanitation.

WIN is in conversation with Catherine Wanjihia from Caritas Switzerland. Catherine is a civil engineer with professional experience in the water sector since 2004. She joined the Kenya programme of Caritas Switzerland in 2011, to work at the field level. She started by interacting in particular with women on a one-to-one basis and learned their local language, as most of them did not speak English. This gave Catherine the opportunity to build a close relationship with them and get a deeper understanding of their role and responsibilities in the water sector and the socio-economic context. Caritas Switzerland has been successfully training community groups in rural areas to manage their water systems by using the Integrity Management (IM) Toolbox since 2014. The organization further supports women with training on hygiene and sanitation. Can you take us through the daily lives of women providing water at the village level in Kenya? Simply put – the provision of water at the household level is the sole responsibility of women and young girls. At the village level, they have to make sure that there is water at home and for animals. They need to allocate enough time for fetching water depending on the distance, which might take up to 8 hours per day. Therefore, if the villages are in dry areas, women might need the entire day to collect water. Transportation of water is done manually and for those who are lucky, donkeys are used. Women also play an important role in creating the local water infrastructure. In Kericho County, the tanks are constructed by women. Women generally support all construction work including tanks, kiosks, protection of water sources such as streams and springs, pipeline excavation, and provision of water (water for mixing cement). Where unskilled labour participation is required from the community, one-third is contributed by women. What are the key challenges they face and how vulnerable are they as women? In the Northern region (arid and semi-Arid land) and some parts of the Rift Valley of Kenya, which is dry, women must wake up at 5:00 am to get water, which means they have to walk in darkness. At the water source, men who arrive later will still demand to take water before the women, because they feel privileged. If a woman needs help to transport water, using a donkey, for example, the men that help her will demand payment, sometimes even in the form of sexual intercourse. In Kericho County, there are few known cases of such kinds of harassment as most of the water collection points are run by women. Water collected from natural sources is free of charge unlike water sourced from piped systems or water kiosks. Women have to ensure money is set aside for water and in most cases they depend on their husbands for the same. In almost all homes, they grow kitchen gardens and ensure they are watered during dry spells. Can you tell us about water management committees and the role they play in the gender and integrity narrative? Most of the Water Management Committees are registered as self-help groups with the department of social services under the County Governments. As such, it is required that one-third of members be women. To fulfil this requirement, women are often given token membership. They rarely make major contributions since the culture does not allow them to disagree with men or to contribute to the discussions. There were instances where women are present in the same meeting but facing different directions away from men. The situation is evolving and one-third of elective positions are now reserved for women according to the Constitution (2010). We see more instances of women being elected into leadership positions. Some are chiefs, chairpersons, treasurers and vice chairpersons. Most community groups are sensitive in terms of gender representation. Do take us through the Integrity Management (IM) Toolbox for small water supply systems and what role have women played in this. The IM Toolbox guides community groups to improve the performance and compliance of water systems, by putting in place better management and governance practices and improving functionality. The implementation of the IM Toolbox is a long-term process and can take between 6 and 9 months depending on the coaching needs of the community and on how well the community is organized and performing. It is called a toolbox because it contains a broad set of tools to select from depending on the problems to address. The IM Toolbox trainings typically go through 3 different phases: the preparation phase, the integrity management workshop and the implementation phase. With the IM Toolbox being put to use, the tide has slowly but certainly begun to shift in terms of gender. To give one example, during the early IM Toolbox training workshops, men and women would sit on different sides and women generally did not speak up. In order to change these dynamics, we made each group i.e. men and women gather separately first for discussions, after which they would come together and present the main highlights from their discussions. We noticed how much more women spoke up and how men increasingly gave women a chance to express their opinions and accepted their ideas. It also increasingly emerged that women are trusted more than men in terms of group finance management hence most committees have women as treasurers. Men have also changed their attitude towards women and are more open to them serving in different positions in the management committee, which were formerly branded as “men positions”. After the workshops and follow-up training, the committees have been setting up book-keeping systems, opening bank accounts, and validating the constitution of the committees, just to name a few measures. All these have led to proper management of the water systems, which has directly impacted women by making their daily life easier and enabling them to engage in other economic and social activities. It has also given women to strengthen their voice by participating in the management and taking leadership positions in the committee. Has involving women through the IM Toolbox brought other changes in the gender dynamics and socio-economic standing of women? The IM Toolbox – apart from transparency and accountability – has also introduced participation as a key component in management. During these participatory meetings, women are vocal because they have realized water issues affecting them directly. This has changed the dynamics of decision-making. In Kericho, I facilitated two to three IM Toolbox workshops. In each group, a leader is usually appointed, called “chief”. In one of the three workshop groups it was a woman. It is very positive and heartening. Even for the higher positions, women are now more often elected and hired, something we would have never dreamt of. Going to higher administration levels, women are getting jobs and governing positions in the Department of Water or other levels of government. When women hold governing positions, they tend to have a more women-oriented approach, and in terms of allocating resources, they are thinking more about women. For example, the Deputy Governor in Kericho County is a woman. Through the IM Toolbox groups that we have trained, we have given her the names of the 70 women involved in the process. She intends to take these women through entrepreneurship courses so that they can become economically independent. These women are not the same women she was dealing with one to three years ago; these are women who are expanding their thinking and horizons and are looking for what they can do for themselves and for their families. What more needs to be done and what are the opportunities? We have a long way to go in improving the social role, norms, culture and acceptability associated with women and seeing the changes where they have a prominent role to play in making decisions. The main challenge for them is the lack of economic independence and empowerment. Women that are empowered and with potential capacity are reluctant to push the envelope because of societal norms. If you look at job opportunities outside villages, most are going to men because women are unable to leave the children and house responsibilities to take work far away from their families. Moreover, men will not agree to stay at home, and women feel it is not what they are supposed to do. A woman is neither encouraged, enabled nor easily allowed to take up a job because it means that she will leave behind her role as a woman in the family, and the family and children will suffer. Therefore, even if there were an opportunity, women would think twice about the advantages and disadvantages of leaving their children. Education can make the situation change – education increases chances of getting a job, seeing other perspectives, “another” world and a life beyond the traditional and constricted roles of women. The biggest opportunity on hand is empowering women financially, supporting them by building their confidence and encouraging them to speak up. Other resources Click here to know more about the IM Toolbox for small water supply systems and case studies from Kenya. See the IM Toolbox video from Kenya.

Practical guidelines on how best to strengthen four governance areas of WEFE Nexus initiatives: Institutions, Information, Investment, and Implementation WHEN TO USE IT When formalising a partnership for WEFE Nexus, to strengthen governance, accountability, and trust between partners. When planning WEFE nexus initiative activities with partners HOW IT WORKS Climate change, population growth, and economic development are straining needs for fresh water, food, and energy. An integrated approach is essential to manage resources sustainably and secure healthy ecosystems. The Water Energy Food Ecosystems (WEFE) Nexus is a decision-making framework recognising interlinkages between sectors and aiming to maximise synergies while balancing trade-offs, for a more sustainable future. Integrity is crucial for the successful implementation of WEFE Nexus programmes and initiatives. Transparency, accountability, participation, and anti-corruption measures provides a path to ensure equitable access to scarce resources, balance competing interests, manage trade-offs, and ensure resources are allocated in the public's interest. These guidelines share recommendations on how best to work towards integrity in four goverance areas: 🏦 institutions - for balanced, accountable decisions; ℹ️ information - for open data sharing and strong capacity; 💲 investment - for safeguarding finances sustainably; ✔️ implementation - for participatory planning, and clear processes for control, monitoring, and reporting. HOW IT WAS DEVELOPED These guidelines were developed with support from GIZ. Download: Contact us for support:

Integrity indicators and reporting frameworks for regulators to supervise service providers. WHEN TO USE IT To raise awareness on integrity risks and their negative impact on the performance of service providers and show paths for building integrity To incentivise water and sanitation service providers for integrity. To benchmark and set standards for crucial integrity measures that can benefit service providers. HOW IT WORKS The indicator framework can be used by regulators with input from water service providers under their purview. HOW IT WAS DEVELOPED The indicator framework has been developed by the Consortium for Integrity in Latin America (WIN, SIWI, and cewas) with support from the Inter-American Development Bank. It is currently being piloted and refined with support from regulators in Ecuador and Honduras. HOW TO USE IT To explore this tool and opportunities to develop and adapt it to your context

A set of resources to launch and facilitate a long-term integrity change management approach in a water and sanitation sector institution, to reduce corruption and minimise bad practice in internal work processes. WHEN TO USE IT To raise awareness on integrity as a lever for improved water and sanitation service delivery and water resource management When an organisation wants to identify and address key integrity risks that may undermine their performance or reputation When an organisation wants to improve performance, undertake internal reforms to strengthen integrity. WHO IS THIS TOOL FOR Regulators Policymakers River basin organisations Water agencies HOW IT WORKS The Integrity Management Toolbox is a set of resources to launch and accompany an integrity management process in a water sector institution. Such a process aims to enable an institution to assess, prioritise and address integrity risks that affect internal governance, project management, human resources, or accounting. Such a process is ideally facilitated by an Integrity Coach. HOW TO USE IT The Integrity Management Toolbox is a flexible toolkit that can be adapted to different stakeholders. It has been used to support water and sanitation sector regulators, river basin organisations, as well as utilities. WIN provides on requet a full facilitation kit adapted to relevant users and guidance on implementation.

Evidence-based planning and action tool that supports water supply and sanitation utilities in improving their integrity practices. InWASH combines a rigorous integrity assessment methodology based on international best practices for integrity in water and sanitation (Integrity Assessment) with a toolbox to prioritise and manage integrity and compliance risks in a participatory and practical manner (Integrity Management Toolbox). WHEN TO USE IT When an organisation wants to identify and address key integrity risks that may undermine their performance or reputation When an organisation wants to improve performance, undertake internal reforms to strengthen integrity, improve customer relations, build trust from users. When a process or project is stalled or integrity issues have come up. To improve internal systematic management of processes, in line with legal and compliance mechanisms, and best practices for accounting or project management. KEY ELEMENTS +40 risk descriptions to spark discussion and engage utitlities, +50 practical tools to inspire action Actionable insights based on objective integrity risk assessment Organisations in the lead: participatory and adapted to needs of organisation Improved internal systematic management of processes, in line with legal and compliance mechanisms, and best practices for accounting or project management. WHO CAN USE IT NGOs and institutions, including local authorities, municipalities and regulators, supporting small water supply systems in rural, underserved, or remote areas NGOs or institutions supporting community-based water supply, HOW IT WORKS Coached process PARTNERS INVOLVED CEWAS, SIWI, IDB PROGRAMME STATUS This programme is currently available in EN and is being developed in ES.

Detailed analysis of integrity management practices and procedures for utilities. WHEN TO USE IT As part of an aquarating process KEY ELEMENTS 6 major principles 16 indicators with different weightings WHO CAN USE IT Water and sanitation service providers / utilities HOW IT WORKS Self-assessment PARTNERS INVOLVED IDB PROGRAMME STATUS Available in EN and ES here: https://publications.iadb.org/en/focused-analysis-business-integrity-water-and-sanitation-utilities

Increasing synergy between SDG6 and SDG16 is possible in Nepal, if stakeholders act now. In 2018, Nepal, one of the world’s youngest democracies, held federal elections three years after the adoption of a federal system in the 2015 Constitution. This federal system, with three levels of government, is now responsible for fulfilling the aspirations of 29 million people and for achieving the SDGs and moving Nepal out of the status of being among the least developed countries. This is a major challenge: twenty-five per cent of the population lives below the poverty line, more than half of the population lacks access to “at least basic” sanitation, and the country is ranked 124 out of 180 in Transparency International’s Corruption Perception Index. But as the country redraws its provinces and builds new decentralized institutions at a provincial level, there is also an immense opportunity for Nepal to tackle its many governance challenges – including those pertaining to integrity and corruption. This is a critical moment: with new institutions come new opportunities and new risks, especially where the capacities of officials in the provinces are still in the early stages of development. Want to know more about our work? New map; new institutions; new risks and opportunities It is often assumed that decentralization processes will have a positive impact in reducing corruption and increasing integrity, due to their potential for increased representativity in decision-making. Research, however, highlights that in some circumstances decentralization can actually result in increased corruption. It is, therefore, a critical juncture in the struggle for increased integrity in decision-making. In Nepal, new government agencies are now being set up in the provinces, where more than 60 per cent of the elected representatives are political novices. A lot of money is going to flow into these institutions, which will be responsible for providing essential services like healthcare, education, water, and sanitation. As this process takes place, it is important to ensure that strong legislation and regulation are implemented and that governance is transparent. It is also crucial that roles and responsibilities be made as clear as possible — in decentralization processes in other countries, such as Kenya, we’ve seen that uncertainty on roles and resource transfers create integrity risks. Officials must be held accountable to ensure that basic services are inclusive and fulfil the tenets of human rights and are not undermined by corruption, nepotism, fraud, theft or any other possible integrity risks. If there are weak governance mechanisms in place, corruption, malpractices, and collusion will thrive and public trust in the new structures will erode. Transfer of knowledge and capacity to new institutions requires support and engagement In the process of decentralisation, there is a risk that knowledge and capacity built up at the national level over years, including integrity, is lost. The Water Integrity Network (WIN) has been working for the past seven years with the Helvetas Swiss Inter-Cooperation and local partners, the Federation of Drinking Water and Sanitation Users Nepal, to support better WASH service delivery, especially to vulnerable communities. The focus of our Water Integrity Programme, which is supported by the Swiss Development Cooperation, is on transparency, accountability and participatory (TAP) practices for improving integrity in the WASH sector. One major programme achievement was the incorporation of water integrity principles into the final draft of the Nepal Water Supply, Sanitation and Hygiene Sector Development Plan (2016–2030). In the document, water integrity is described as the adherence of water stakeholders and institutions to the principles of transparency, accountability and participation, based on the core values of honesty, equity and professionalism. The plan also refers to the need for both vertical and horizontal accountability across the WASH governance structure. Integrity, by requiring that public interest be paramount, provides the basis for accountable WASH projects and service delivery. For good accountability in WASH services and operation it is necessary that politicians, policy-makers and WASH service providers are transparent, accept responsibility for their actions, and recognize that they should be called upon to give an account of why and how they have acted or failed to act. However, due to the decentralization, this national draft WASH sector development plan no longer has strong ownership within the government and there is a risk that it might be abandoned. There is now an urgent need to translate the national policy principles into provincial planning documents. Building the capacity of local stakeholders The Federation of Water Users and Sanitation Users Nepal (FEDWASUN) has been an essential partner of the Water Integrity Programme in Nepal. Special attention has been given to building the voice and capacities of its members around Transparency, Accountability, and Participation. FEDWASUN is a federation of water and sanitation user groups that are responsible for service provision and tariff collection at the local level due to the very limited capacity of the government. They work closely with government agencies. Due to the current changes in roles and responsibilities, FEDWASUN is being restructured but there is still no clarity on how the new relationship with the government will evolve. These changes, and the incorporation of new people into FEDWASUN who were not part of the integrity training, can result in the integrity capacity and focus of FEDWASUN being diluted or even lost. It will be important, at the local level, for the administration to collaborate with FEDWASUN to ensure that the capacities and knowledge of FEDWASUN members can continue to support the government agencies in strengthening integrity and governance in WASH service delivery. Renewing engagement for sustained change The Water Integrity Programme in Nepal has been supporting the transition to the new federal structures, ensuring water integrity principles are embedded in action plans and that the capacity of right-holders and duty-bearers is enhanced. While the project was originally focused on national and district levels, due to the establishment of the new provinces, the focus of the work needs to shift. Unfortunately, the current water integrity programme is ending at the end of July 2019, at a crucial time in Nepal’s democracy. However, moving forward, Helvetas Swiss Inter Cooperation has committed to mainstreaming water integrity in their Water Resources Management Programme (WARM-P) to ensure that stakeholders are able to translate integrity principles into action and to transfer their learnings to other INGOs and CSOs involved in developing water user master plans. WIN will also continue engagement on the topic of water integrity and explore opportunities to strengthen collaboration with partners on increasing integrity and reducing corruption in WASH. We are actively seeking new engagement and partnership opportunities. For Nepal WASH sector stakeholders to capitalize on past learning and get on track to achieve #SDG6, a top priority is to focus simultaneously on #SDG16 and tackle governance issues to strengthen institutions. The time to support integrity initiatives in Nepal is now.