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WIN’s latest resource is an introduction to the topic Land and Water Grabbing: A discussion of integrity implications and related risks, which discusses the integrity implications and risks of land and water grabbing. The essay examines the link between land and water grabbing, the people that are most impacted by this, and legal frameworks related to both land and water rights. Land and Water Grabbing describes the impacts of land and water grabbing in Kenya and Ethiopia. It examines integrity risks in the Ethiopian government’s leasing of land and water resources to foreign investors, and the land reform process in Kenya after the launch of the 2010 Kenyan Constitution. This summary document identifies how powerful actors are taking control of land and water resources at the expense of poorer, local communities. Land and water grabbing refers to the capturing of both land and any water resources that the area encompasses. Corruption in land governance plays a huge role in land grabbing, and integrity risks manifest through bribes, flawed decision-making processes, circumventing official procedures, and institutional fragmentation. This resource was developed by Carmen Fernandez Fernandez (WIN Associated Consultant) with inputs from the Centre for Rural Development (Seminar für Ländliche Entwicklung, SLE). Download the full document:

Working paper Published in 2017 By Binayak Das (WIN), Elske Koelman (WIN), Claire Grandadam (WIN), Frank van der Valk (WIN), and Grit Martinez (WIN associated consultant) This working paper outlines key risks that limit transparency, accountability, and participation in wastewater management, letting corruption thrive. Drawing on several case studies from different regions, it illustrates how these risks play out, what can be done to address them, and the difficulties involved in doing so. Download (pdf, EN)

AGREEMENTS AMONG PROJECT OWNERS, BIDDERS/CONTRACTORS, AND CSOS TO ABSTAIN FROM ILLICIT PRACTICES Integrity pacts are agreements between project owners and bidders that they will abstain from bribery, collusion, and other corrupt practices during their bidding and for the duration of the contract once awarded. Integrity Pacts include a monitoring system typically led by CSOs. Integrity Pacts are meant to detect and eliminate corruption risks from the procurement and contract management processes. The breach of an integrity pacts should trigger sanctions for those involved. In the case of a contractor, this could imply loss of contract, fines, and debarment from future tenders. These sanctions are a powerful deterrent for corrupt behaviour. HOW IT WORKS The distribution of responsibilities between the project owner and the bidder/contractor is individually arranged for each integrity pact, which is why there is no one-size-fits-all recipe. Nevertheless, every integrity pact process should involve the following steps: Learn about the integrity pact and issues of corruption in public contracting in the water sector, and read about successful examples. Plan the integrity pact process (when to start, who to involve, communication, etc.). Undertake initial activities, such as deciding on implementation arrangements and monitoring arrangements. Prepare the integrity pact documents and make sure to have appropriate legal support. Sign the integrity pact (project owner and bidders, etc.). Monitor the procurement process and take action if the pact is breached. Once the bidding is closed, ensure that contract execution is in line with the obligations set in the integrity pact. RESOURCES See the Manual - What is an Integrity Pact and how can it be implemented Also available in French: Training guide for facilitators:

LESSONS LEARNED FROM THE IRRIGATION SECTOR IN INDONESIA Brief By Michael Dunford, Diana Suhardiman, and Peter Mollinga Published in 2017 with IWMI This joint WIN and IWMI brief discusses the characteristics of corruption in the Indonesian irrigation sector, in particular of the upeti practice: a complex, institutionalized system in which subordinates are expected to funnel resources upwards to their superiors in exchange for better positions and social benefits. Understanding the dynamics of such a system is crucial to realign and better target our anti-corruption work. Standard approaches focused on lessening the financial appeal of corruption will not be as effective for corrupt practices that have become intrinsic to how work relations are structured and developed. This brief points to a paradigm shift in how we address corruption, with a more critical, politically and culturally-oriented approach. Download (pdf, EN)

In 2013, the eight-story Rana Plaza building, which houses many garment manufacturing units in Dhaka, collapsed, leading to the death of more than a thousand workers. The primary reason for the collapse is a structural fault, which itself is due to non-adherence to prescribed standards for buildings. This incident brought international attention to the garment industry in Bangladesh, where clothing is manufactured for some of the world’s most famous brands. This led to numerous efforts to raise concerns and address challenges that exist within the garment and textile manufacturing sector in Bangladesh: human rights violations, poor work environment, flouting of laws, corruption, and public and environmental health damage. The violation of pollution control laws with the discharge of untreated wastewater into Dhaka’s rivers and lakes is one such key challenge. In early 2017, Transparency International Bangladesh (TI-B) and the Bangladesh Water Integrity Network (BAWIN) with support from WIN, undertook a study to understand the integrity concerns around the implementation of laws to protect water bodies from garment industry pollution. The study Use and Effectiveness of Effluent Treatment Plants (ETPs) in the Garments’ Industry of Bangladesh: a Water Sector Integrity Perspective was published in June 2017. What does the study reveal? This report points towards poor implementation of laws, inadequate monitoring from government agencies, and factories’ underuse of ETPs. These wastewater treatment plants are the basic treatment facilities that are required to treat effluents at a factory before discharge. They help in reducing the biological oxygen demand (BOD) and keeping water bodies healthy. In the case of the use of dyes and colours, the ETP with additional features functions to reduce the chemical oxygen demand (COD) too. The rivers around Dhaka city are already polluted by textile effluent. While production increases day by day, ETP performance has not. Buyers push to drive down prices so factory owners look for ways to cut costs. Improving ETP performance becomes less of a priority, especially as space is limited in garment factories, an additional constraint. The other side of the garment industry growth engine The textile and garment industry is a major driver of the Bangladesh economy, accounting for nearly 80% of export earnings and contributing more than 12% of the national GDP. ‘Made-in-Bangladesh’ is an internationally recognized badge of quality and has bolstered the country’s image worldwide. Annual turnover of nearly 23 billion USD is predicted to more than double to 50 billion USD by 2021. The textile firms contribute to the wealth and prosperity of the country but in the process, they are destroying the surrounding environment on which farmers and others depend for their livelihoods. According to the Ministry of Environment and Forests, the water of the rivers surrounding Dhaka city where wastewater is discharged without adequate treatment is highly polluted. The rivers have been characterized as ecologically critical areas. Few textile factories in Bangladesh maintain wastewater treatment processes at the necessary level to meet discharge standards. - Discharge of wastewater from garment factories in Bangladesh. Copyright: enrac. Legal provisions for ‘red industries’ and their implementation Under Bangladeshi law, the garment industry falls under ‘red industries’. These pose the highest environmental threats. Environmental law mandates that all Red category wastewater producing industries, including textile dyeing plants, must use Effluent Treatment Plants (ETP) to treat wastewater before discharge. Factories must also obtain an Environmental Clearance Certificate (ECC) by conducting an Environmental Impact Assessment (EIA) and having it approved by the Department of Environment (DoE). Prior approval is also required from the DoE before designing and starting a high-polluting industry, including textile factories. But going by the new BAWIN and TI-B study, there is no effective EIA system and the DoE only published non-statutory guidelines for industrial projects. This weakens the compliance mechanism to ensure the proper implementation of environmental laws. The report further states that the Environment Management Plan is not followed in the day-to-day operations of a textile factory. There is only a low chance that a factory will in fact be penalized for failing to meet environmental standards. More than 70% of respondents in the study said that environmental laws are not implemented properly. Regulatory weaknesses Why are environmental laws not implemented properly? According to the Dhaka Watershed Report of the World Bank (2011) the DoE, like the national regulatory agency, is acutely short of manpower and logistical resources. Polluting factories are seldom inspected. Communities living around industrial clusters informed the report authors that inadequate monitoring and inconsistent enforcement are the main reasons for the fact that factories dispose of untreated effluent into wetlands or rivers. It was reported that agencies often do take mild actions but appeals by industries lead to withdrawal or reduction of punishment. In community and stakeholder consultations, it was suggested that ambiguity and corruption may cause these irregularities. As a result, farmers, fishermen, and others who rely on water bodies have seen a reduction in their livelihoods and an increase in the prevalence of diseases. On the positive side, there have been efforts to address some of these issues. For example, since 2010, the DoE has deployed mobile magistrates, which help sanction more polluting companies. There are still big gaps, however. A review of the National Water Act 2013 for Bangladesh conducted by the global apparel brand H&M identified a number of issues and made recommendations that may offer useful ways to improve water sector integrity through improved effectiveness of ETPs in the textile industry. The report claims that it is less expensive to pay penalties than to invest in ETPs. Legal weakness put the entire enforcement system at risk of inefficiency and corruption. As long as weaknesses and loopholes exist, polluters will bypass wastewater treatment to gain higher profits. Underperforming ETPs The BAWIN and TI-B report estimates that the proportion of factories with ETPs is between 40 and 80%. It has been reported that the volume of wastewater generated by factories is within the capacity of the ETPs used by the textile industry. However, it is widely acknowledged that many of the installed plants are not designed according to standards or are not operated in an appropriate and responsible manner. The main factors causing this poor performance of ETPs are a lack of knowledge and technical capability, a lack of monitoring, and poor record keeping. Owners are also often reluctant to run ETPs effectively full-time to minimize the costs of the expensive chemicals consumed in the treatment process. There are no accountability mechanisms. Factory managers and regulators consulted for the study expressed different views regarding the problems in inspection processes. Factory managers indicated that the frequency of inspections varies between factories, as does the quality of the inspections. In some cases, water samples are not collected and no action is taken if a factory is non-compliant. Sometimes, additional unofficial payments are required for environmental certificates. It is also reported that there are cases where officials seem to have put pressure on company owners by creating false test reports. DoE officials report that inspection officers do not always get adequate support from factory managers. Sometimes inspectors are barred from entering factory premises or managers delay their entry so that ETPs can be turned on. Some factories conceal drains through which they dispose of untreated waste. Punitive measures are difficult to implement because of weak political willingness to impose punishments or appropriate actions for environmental violations. When the violators are politically active they can bring strong pressures to bear on the regulatory bodies. - Water quality testing of polluted water sample for ETP evaluation study. Copyright: enrac. Integrity in the garments industry: everyone needs to do more The rich set of policies and laws that Bangladesh has should provide should be a strong backing for better wastewater management for the garment industry. Enforcement is too weak, however. The report shows a clear lack of transparency and accountability in environmental decision-making processes in Bangladesh. Weak governance has resulted in undue influence on state institutions to achieve growth rather than sustainable environment management practices. For the country to reach its ambitious SDG goals, it will be crucial to address these challenges. The government must enforce its rules and make sure industries comply. There is space for an advisory and regulatory watchdog in this sector to oversee activities and make suggestions for improvements, undertake advocacy campaigns, and enforce action against violations. Factories have corporate social and environmental responsibilities and they should comply with rules that can be rewarding and sustainable for them. The international agencies that are investing in the improvement of governance in the garment sector and reputed global brands that source their garments from the country need to take this issue up urgently to ensure that public health, workers’ rights, and healthy ecosystems are protected and need to contribute to strengthening integrity within the garment industry. Political commitment, skilled human resources, and institutional capacity are all required to ensure proper enforcement of rules and regulations for pollution control and protection of the environment. Report recommendations Transparency: Greater transparency requires strengthening rights to information and researching the extent of social and economic damage. Greater clarity and definitions are needed on the responsibilities and licensing and enforcement powers such as those currently divided between the Departments of Textiles and the Department of the Environment. Adequate enforcement of water regulations requires full-time monitoring of effluents and ETP functions. Awareness needs to be raised among textile owners and their Apex Organizations about pollution and their legal and social responsibility to prevent it. The DoE should make Local Government Institutions aware of how to use their powers to minimize pollution and support Upazila Fisheries Committees in ensuring acceptable water quality in wetlands and fishery areas. The DoE should accredit and appoint competent third-party organizations to monitor textile companies regularly on its behalf in addition to conducting its own monitoring. Accountability: Greater accountability requires clearer lines of responsibility and stronger sector capacity. Greater integration of responsibilities by the Ministry of the Environment and Forests with related ministries will help to identify common goals and start a dialogue on strengthening institutional ownership. A review of the ECA 1995, the ECR 1997 and the Water Act 2013 is needed to establish a consistent approach to conducting EIA and issuing project approval for water-related projects. The DoE needs the skills, staffing levels and resources required to perform its watchdog and enforcement roles, especially in monitoring Environmental Impact Assessments. The country should incorporate a market-based ‘polluters pay principle’ system with appropriate economic incentives, rewards, disincentives and penalties. The Water Resources Planning Organization (WARPO) requires a clearer mandate and the resources to operate a project approval system with integrity. Participation: Participation must ensure places at the table for civil society, the private sector and excluded groups to balance stakeholder interests. An appropriate system is required for public consultation to ensure informed decision-making and grievance redress, especially for local people affected by water pollution. National and community-level bodies should be established and validated to monitor the water quality of khals, beels and rivers, and the results used to determine anti-pollution measures, operating permits, and actions (including legal actions) against offending industries. Anti-corruption: Corruption can be tackled by ensuring a stronger role for regulators and making participation and transparency mandatory. A licensing system for industrial withdrawal from groundwater sources is required with a strong monitoring system by the DoE and the Water Resources Planning Organization (WARPO). The DoE regulatory bodies should be decentralized and strengthened to monitor effluent treatment plants and systems. The DoE and WARPO should create a more effective mechanism for penalties, such as fines, loss of tax and duty concessions, blacklisting or even removal of operating licenses. Environmental courts should be strengthened to ensure the punishment of polluters. Administrative interference should be minimized to decrease corruption and increase transparency. The legal process should be simpler and quicker when action is taken against the alleged improper extraction of water or pollution. Download the full report: Thank you We would like to thank all contributors to the study on the Use and Effectiveness of Effluent Treatment Plants (ETPs) in the Garments’ Industry of Bangladesh: a Water Sector Integrity Perspective, in particular the authors—ENRAC, Transparency International Bangladesh, BAWIN— and Peter McIntyre, for his editing and review.

WIN launched a baseline study to map integrity and corruption risks in the water and sanitation supply in Benin in March 2017. The study is based on the results of participatory assessments of Transparency, Accountability, and Participation (TAP) for water and sanitation, which are being carried out using the Annotated Water Integrity Scan (AWIS) tool. Using AWIS is a way to quickly gather information on perceived levels of TAP without letting results be overtly skewed by the perspectives of stakeholders with the loudest voices. The tool helps different stakeholders examine in particular: policy and legislation, regulation, projects and investments, service delivery, and anti-corruption in the water sector, in terms of TAP. A workshop on urban water was held in the capital Cotonou, June 7th to 8th, with 45 different stakeholders of urban water and sanitation supply in Benin. Of the three pillars of TAP, Accountability scored lowest at the workshop. Participants were of the opinion that the legal framework is in place and available, but that enforcement is too limited, giving way to corruption and abuses of all kind. These first insights will be completed with additional information from the findings of other AWIS workshops in other sub-sectors, as well as data from household surveys and case studies. The final conclusions will be published before the end of the year. First high-level forum on good governance in Grand Popo, Benin (15-17 June 2017): participants confirm the need for better oversight and more capacity for the judiciary The First High Level Forum on Governance was organized to assess the work done in terms of fighting corruption and promoting integrity in the public sector in Benin. The Constitutional Court of Benin and FONAC (Front des Organisations Nationales Anti-Corruption) led the forum with the financial support of USAID. 150 participants came together from the government, private sector, civil society organizations, donors, and the media. The findings of the Forum are in line with those of the AWIS workshops so far. Participants concluded that a legal framework is in place but that enforcement is weak and capacities for enforcement are woefully insufficient. There are currently only 150 judges for the whole country and three financial auditors to scrutinize public accounts. Impunity is an issue. A set of recommendations was released at the end of the forum: Learn from integrity promotion activities in the water sector and conduct an integrity risk and corruption map in every sectoral department to define priority actions to be taken. Use Integrity Pacts as a public procurement tool to promote transparency, accountability, and participation, and prevent corruption. Enhance the human and financial capacities of the judiciary. Implement all the recommendations from the assessment of the National Integrity System in Benin. Their implementation of these recommendations will be assessed at the next edition of the forum in 2018.

Uganda has placed integrity in the water sector high on the development agenda by pursuing an explicit good governance strategy in the provision of water supply and sanitation services. In 2006, the Ministry of Water and Environment (MWE) established a multi-stakeholder Good Governance Working Group (GGWG) tasked with recommending specific measures to promote and monitor transparency, accountability and good governance. Since 2009, GIZ has supported the GGWG with Technical Advisory services, such as those of current Good Governance Advisor Rosemary Nakaggwa, who has supported the sector in developing governance indicators. This is in addition to GIZ’s support for the development of an independent regulatory authority in Uganda. To discuss their views on integrity and their take on the progress that the GGWG is making in promoting integrity in water in Uganda, we caught up with Rosemary Nakaggwa and Eng. Gilbert Kimanzi, the former chairperson of the GGWG and current Assistant Commissioner under Water for Production in the Ugandan Ministry of Water and Environment. An interview with Rosemary Nakaggwa and Eng. Gilbert Kimanzi. Why is it so important to work on water integrity in Uganda? Gilbert: It is important to work on the promotion of water integrity issues because you want to measure the effectiveness of the delivery of services. If you do not promote integrity, there is a lot of leakage and waste. We advocate to deliver: once we get the resources, we need to put them to good use, and this needs to be measured. We have to do this effectively and efficiently because we are not anywhere near our targets. Since you have begun working on promoting water integrity, what do you feel are the most significant changes that have occurred in the water sector? Rosemary: There is more sharing of information and I see people trying to be more accountable at various levels. The issue of corruption is still a very big one, not only in the water sector but also at a broader level in the entire country. Corruption limits the improvements in terms of Transparency, Accountability, and Participation, but at the same time, the work on TAP is reducing the breeding grounds for corruption. Gilbert: The most significant change is the recent development of indicators on good governance and integrity. Specific indicators have been developed, against which we measure progress in governance in the water sector. The other change that can be noted is that, over the years, we have developed a culture of measuring the cost of delivery of services. The sector is not very well funded, but the unit cost of the delivery of services needs to be checked. We check whether costs go up, and monitor why this happens. We have been doing this for the last 7 or 8 years. We also track grants that were sent to local governments. We now have an institutional framework to track those grants and to look at the effectiveness of the delivery of services using those grants. Those grants cover rural water supply and sanitation, operation and maintenance, and work done in small urban centres. We are also looking to monitor grants for sanitation development. What other specific activities have you been carrying out to promote integrity? Can you give examples? Rosemary: In Uganda what has been done through the GGWG has been to first of all increase awareness of Transparency, Accountability, Participation, and Inclusiveness. This was done through training that were designed specifically for the water sector. We launched awareness campaigns with partners that have helped make governance a more common topic of discussion at meetings. We also conducted studies to evaluate existing guidelines and to what extent they involve integrity components. For example, when looking at the allocation of grants, we evaluated whether there is equitable distribution of the grant to all regions. Guidelines were redesigned to take into account the conclusions on how inequitable the allocation was. An integrity risk mapping was carried out too. Can you tell us more? What was the added value of such a mapping? Rosemary: The risk mapping was done in 2009, to help better target resources and identify priority areas on which the sector should focus. The allocation of responsibilities was then also identified as a key issue. The plan is to have another study to see to what extent we have achieved our targets and to see whether we still face similar risks as compared to the start. However, the focus will also have to be more on anti-corruption, even though corruption is a cross-sectoral issue that is, therefore, more difficult to tackle. Gilbert: The first thing we developed is a baseline, indeed. If you are going to measure something, you better have a baseline. We established an action plan, which has actions for different sub-sectors which are monitored on a quarterly basis. Progress is then reported to the water sector working group, where senior officials are involved. Monitoring per quarter has been good practice and is significant. We have also raised the profile of the leadership of the GGWG: the GGWG is now a recognized sub-sector working group. Recently, I handed over the chairmanship of the group to the under-secretary in charge of finance and administration in the Ministry of Water and Environment. The GGWG has been trying to help set up an independent water regulator in Uganda. Where do you see the big challenges and opportunities with such an action? Gilbert: I would say the biggest challenge is that the National Water Sewerage Corporation does not want a regulator. They feel they would be put under scrutiny. They deliver services but they don’t want to be accountable to the customer up to the last dollar. They do all sorts of things to delay the setting up of the regulator. However, every service or measure should be regulated. You need a good regulator who sets standards and tariffs and ensures that the quality of service is monitored and budgets are approved. There is a big demand and opportunity for it, but we have been dragging our feet. Rosemary: I think from my perspective, when you look at integrity and the totality of good governance, we definitely need to have contracts in place and agree on guidelines and principles in a participatory manner. This can only happen if there is a clear separation of roles, from the service providers, implementers, policymakers, water providers, and water users. You need to have a body that tries to ensure that all parties involved do not compromise each other or do not end up abusing each other, because one party might be more powerful than the others. This is the regulator. The will to set up such an independent regulator is maybe not entirely there yet: Uganda as a country still has many challenges. What are the plans of GIZ and the Ministry to assess the good governance indicators? Gilbert: We are working with the focal point officers on the indicators on integrity. What we have done and continue doing is that every focal point officer needs to keep track of the progress made in implementing the recommendations in relation to these indicators. Someone from the GGWG meets with these officers to check what is being done. Indicators 4 and 5 on budget allocation, for instance, are reported on a monthly or quarterly basis. Someone from the secretariat checks the quarterly progress reports and compares the data. We need to look at sustainability so that each sub-sector continues to provide the data. Sometimes we want to carry out a one-month assessment to see whether data is coming but are limited by personnel and financing. What are the next steps? How do we move forward for integrity? Gilbert: Strengthening the secretariat of the GGWG is a first step. Not many people like to talk about governance, and good governance and integrity are not the first point of call. Strengthening the secretariat is one of the affirmative actions to bridge the gaps we still face. We have a lot of support from technical advisors, but it should also involve more financing to get tracking studies going. The key is to also strengthen the personnel and budget of the GGWG. Moreover, raising the profile of the GGWG and working on good governance and integrity is also crucial, for instance by putting someone higher in the hierarchy to take over the chairmanship of the GGWG. And of course, we must continue to ensure that recommendations and progress reports are submitted to the sub-sectors. Rosemary: We first focused on making sure duty bearers perform to the best of their abilities. Some still act irresponsibly and abuse is visible. It is a priority. But now, I also see an increase in the awareness of rights holders. More people are getting to know their rights. The challenge is for them to implement or demand such rights given the environment. We need to focus more on getting back systems of action, effective monitoring, rewards for good work and sanctions where necessary. As the duty bearers are trying their best to do their work, the right holders also should have the capacity to demand for better services. An independent regulator will in this regard be important. Thank you! (These interviews were edited slightly for clarity.)

The XVI World Water Congress took place in Cancun, Mexico, from the 29th of May to the 3rd of July 2017 with “Bridging Science and Policy” as a topic. During the event, more than 1100 participants from 68 countries discussed the crucial role that the water and sanitation sector has in achieving the 2030 Agenda for sustainable development. WIN presented work led in collaboration with The Nature Conservancy (TNC) in Latin America, which is aimed at strengthening transparency and trust in stewardship initiatives like Water Funds. Science is by definition a neutral discipline based on experimental data and independent of political ideologies. But policymakers can be reluctant to accept scientific facts as primary evidence for policymaking, especially if these facts contradict special interests or are poorly understood. Two factors worsen this situation: the possibility to manipulate and distort data to fit certain interests, and the complexity of science for a non-specialized audience. The combination of these two factors can decrease people’s trust towards science. The intense political debate on climate change sciences is an obvious illustration. At the time of the Congress, the United States government announced its official withdrawal from the Paris Agreement. Although not a surprise, the news struck participants, resonating as a deep failure in the fight for protecting the planet from the negative impacts of climate change. A key ingredient for bridging policy and science is integrity. More transparency, accountability, and participation can help build trust and reinforce the synergy between science and policy. It is essential that water sector stakeholders take into account integrity principles and conflicts of interest more seriously, use science as evidence for better policymaking and steer scientific enquiry towards the most pressing social needs. Clarifying links to integrity risks when we discuss key water sector issues and policy solutions, can be a strategy to innovate and plan new ways of bridging the gap. In Cancun, this possibility remained implicit for now, but some stepping stones were set. It’s up to us water integrity practitioners to push further and clear away a more inviting path. Integrity is an implicit, cross-cutting issue in the water sector Water security was on everyone’s lips at the Congress. We heard it in the context of Integrated Water Resources Management (IWRM), the water-energy-food nexus, and water governance. In every case, water security conveys a central message: we need to make sure that water is and will be available to sustain livelihoods, human well-being, and healthy ecosystems. In many sessions, the examples that were presented in relation to water security were about conflicts or success stories of shared water resources around the world. Sharing scarce resources fairly and sustainably is central to the concept of water integrity and as such water security is very closely connected. Without a direct reference to integrity, participants also expressed their interest in many other integrity-related topics, for example: The lack of data on people not accessing water services, compared to the availability of data on water users. The few incentives to reduce non-revenue water, compared to the relative ease of getting investments for new infrastructure. The way better information does not necessarily imply better decisions because of the complexity of the decision-making process The importance of accountability to increase investors’ trust. The key role of civil society in fighting corruption and the challenging environment for such work. In relation to the last point, the Cancun Declaration released at the end of the event does urge for collaboration and engagement, in particular with civil society. It’s a small step in terms of recognizing integrity risks explicitly but a step in the right direction nonetheless. ‘They (water specialists) must engage with civil society to assert the role of water in human rights and nature.’ – Cancun Declaration Paths to introduce integrity into the water discussion Congress participants intensively discussed the water-related goals of the 2030 Agenda for Sustainable Development. The discussion highlighted the importance of interdisciplinary collaboration and the ‘3 “I”s’: Institutions, Infrastructure and Investments. It is important to note that these 3 elements relate to important integrity risks: misuse of key positions, bribery and collusion in procurement, and lack of transparency in the public budget. Integrity can be a new way to think of issues at hand and jointly develop fair, effective, and sustainable solutions. Water governance is another important and clear entry point. Good governance and water integrity go hand in hand. The Organizations of Economic Co-operation and Development (OECD) presented their latest work from implementing their principles on water governance, which emphasise integrity, transparency and trust. The new phase of the OECD Water Governance Programme includes a platform where water practitioners can share their experiences. The aim is to activate a fruitful dialogue for water governance. Integrity to support and enable water stewardship: integrity in Water Funds In Cancun, WIN presented the work it has carried out with TNC and the Water Fund of Medellin, Colombia. Water Funds are water stewardship initiatives in which public and private actors work together to provide water security to metropolitan areas by investing in natural infrastructure. These initiatives have been very successful and are currently considered a model of good practice. Many sessions during the Congress discussed different aspects of their structure. Water Funds rely on technical and scientific data to design their action plans. But such collaborative basin management also requires mechanisms to ensure open accountability, participation, and clear access to information for all stakeholders involved. Open collaboration and knowledge sharing among Water Fund stakeholders have been essential to their success. This relies on trust. WIN’s work on Water Funds (and World Water Congress presentation) focused on: The importance of trust and transparency as essential elements for the success of multi-stakeholder processes; The joint efforts of WIN and TNC to make Water Funds more transparent, secure and participatory; How a better understanding of the success of these initiatives in terms of integrity and effectiveness will be paramount to securing investments and fine-tuning their multi-stakeholder structures. The presentation led to a lively discussion. Some questioned the importance of participation, particularly that of civil society and of the youth. In response, we highlighted the big challenges for water governance in places where civic space is constrained and the importance of new technologies towards transparency. We argued that the experience of the Water Funds is a good example of how important it is to understand the positions, needs and interests of all actors.

Collective and organized action is crucial to reduce corruption and inefficiency. Water Funds are a good approach to make this a reality. – Mr. Alejandro Calvache (TNC) The Nature Conservancy (TNC) is a charity organization that works globally to protect ecologically important lands and waters for nature and people. TNC works together with communities, businesses, governments, multilateral institutions and other non-profit organizations. TNC launched the Latin American Water Funds partnership across Latin America and, more recently, Water Fund projects in North America, Asia and Africa. Water Funds are a model of long-term environmental conservation for watersheds that supply water to cities and communities. Mr. Alejandro Calvache is the coordinator of the Water Funds programme* in The Northern Andes and Southern Central America Region. He leads the use of technical and financial tools to promote long-term conservation schemes of supplying water basins. The governance of water supply systems has always been a pivotal theme for TNC, especially in Latin America. As a consequence, integrity is both a concern and a target. Water Funds are meant to offer a solid and transparent structure to channel public and private funds into trustworthy platforms for conservation initiatives. In this context, integrity can a) increase the effectiveness of such platforms, b) help achieve greater credibility and reduce reputational risks, c) foster long-term engagement with investors and communities, and d) build more trust among involved stakeholders. We conducted an interview with Mr. Calvache, who has worked with TNC for almost ten years, to find out why Water Funds have been so successful and what challenges TNC still faces in further promoting water integrity in the water sector of Latin America. How is TNC currently contributing to transparency in the water sector in Latin America? TNC has advanced a game-changing approach to improve key ecosystems responsible for water provision in several cities across Latin America. The Water Fund approach combines state-of-the-art science, better governance models, economic principles and collaboration with key stakeholders from the public and private sectors as well as civil society. This encourages participation and transparency in the water sector in Latin America. By focusing on the governance of water provision, TNC is committed to ensuring that water is used and supplied in a transparent manner, where all investments are glassy and expenditures are properly tracked. In Water Funds, large water users in cities like Bogota, Medellin, Quito, Rio de Janeiro, Mexico City and others, now invest in watershed protection projects. These projects are varied and can focus directly on reforestation or also contribute to helping local farmers improve their practices and diversify their income. By reducing the flow of sediments into the water, such activities have led to improved water quality at a fraction of the cost of building water treatment plants. Nature benefits from these projects too: restored forests and grasslands are key to capturing water and sheltering wildlife. To date, TNC has established 20 Water Funds in Latin America, which seek to increase public-private partnerships and collective action to increase transparency in water management. What current and future challenges do you see to reducing corruption in the water sector in Latin America? With regard to current challenges, we see the difficulty for public and private water-related initiatives to be articulated in an organized manner. We are working very hard to avoid dispersion. Collective and organized action is crucial to reduce corruption and inefficiency. Water Funds are a good approach to making this a reality. As for future challenges, these relate more to the ability to secure long-term financing for watershed conservation based on nascent water regulation frameworks, with clear control mechanisms in which civil society plays a permanent role. What factors have ensured that the Water Fund in Medellin has become so successful? First, the commitment from key stakeholders from the early stages of the design phase was crucial to setting up a successful Water Fund in Medellin. For example, Empresas Publicas de Medellin, the environmental authorities, and the private sector were strongly involved from early on. Second, cutting-edge science helped identify Water Fund goals in terms of areas for intervention and return on investment. Third, a clear and balanced public/private governance model established to operate the Water Fund was crucial. Finally, permanent dialogue between different Water Funds within Colombia and across the Latin-American region plays an important part in ensuring that the Water Funds operate successfully. What did the collaboration between TNC and WIN bring so far to the already ambitious objective of the Water Funds? The collaboration between WIN and TNC has brought additional tools that help evaluate and improve the performance of Water Funds. A first gulp from the glass of water integrity, which also helped in starting this collaboration, was the analysis of the governance structure in the Medellin Water Fund. The collaboration between WIN and TNC allowed the Medellin Water Fund team to assess current results and propose solutions to increase efficiency and transparency. Both these elements are very important to build trust and secure Water Fund operations in the long run. We are exploring how to use the methodology in other operational Water Funds in Latin America. There are several actions that TNC wants to focus on in the future to further promote participation and transparency in the way Water Funds operate. These actions have been explored in collaboration with WIN. We want to further strengthen governance models of operational Water Funds. This could mean defining clear enabling conditions for consideration before the design of new Water Funds, to make sure any new Water Fund is efficient, transparent and sustainable. TNC will also be implementing robust science-based monitoring protocols to quantify key impacts in water quality, water regulation, and economic and socio-economic benefits delivered by Water Funds on a regular basis. Where do you see key areas of collaboration with the Water Integrity Network in further pushing for more integrity in the water sector of Latin America? Together with the WIN, we see opportunities to share best practices, lessons learnt and experiences in designing Water Funds in the region. TNC would like to replicate the Water Fund model in different geographies across the world. Collaboration with partners can help us jointly improve the health of watersheds and can play a role in increasing the scale of results in watershed conservation initiatives. The experience WIN is bringing into this partnership transcends the mere integrity assessment and supports the need for more participated approaches in funding the water sector. WIN can help TNC in identifying replicable ways to ensure the right balance of interests gravitates towards watersheds. And, since WIN is a global network, strong collaboration is essential to reach such a scale across the world. *About The Water Fund Programme Water Funds operate through investments and leveraged resources generated and assigned to preserve the basin through conservation actions. These funds aim to invest in nature to increase water security in 40 Latin American cities by 2020. These investments are focused on keeping intact natural areas, restoring the lands along the watershed and river corridors and implementing management practices that minimize the impacts of the activities of land use in the quality and quantity of water. The Water Fund in Medellin, Colombia is one of the most successful Water Funds in the region. This particular Water Fund is capable of collecting public and private funds for the conservation of the watersheds providing water to Valle de Aburrá, including the City of Medellin. In early 2016, WIN discussed with TNC the possibility of making Funds even more transparent, secure for investors and communities, and capable of building trust among stakeholders. It is crucial to have mechanisms to strengthen accountability and promote different levels of participation, to ensure that people of the basins can have access to relevant information on results.

In honour of the UN-Water year on ‘Wastewater’, WIN is posting a series of guest blogs on the topic. Community participation and citizen activism are vital for successful river management and for ensuring clean and healthy rivers. Citizens are best placed to demand accountability from authorities and their political leaders. Often, they bring innovation and wit into their campaigns. The love letter campaign against wastewater discharge An interesting example relates to a citizen movement against wastewater discharge that occurred in the Brantas river basin in Indonesia. A few years ago, 17-year-old Zaskia Dwi Aridhiyant was part of a youth group involved in fighting river pollution. She made a unique move to highlight the mismanagement of wastewater in the area around her school by initiating a campaign called A Love Letter for the Governor. Zaskia gathered 15 students from her school, SMAN Driyorejo, to help monitor industrial wastewater discharge in the area. With a simple water quality test kit and camera for biomonitoring, her group collected samples that detected high levels of harmful pollutants. With the results in hand, the students then sent a ‘love letter’ to the polluting industries about their violations. This letter stated that if the industries would take measures to handle the waste discharge and would respond, Zaskia would send them chocolates as a sign of appreciation. Several industries replied to the love letter and committed to improving their wastewater management. But more than 60% of the letters were left unanswered. Unsatisfied with the result, Zaskia took the movement to another level. She gathered support by asking people to sign her love letter to the Governor of East Java, Sukarwo. Every week over a period of three months, Zaskia campaigned in the city park to collect signatures for her letter to the governor. Eventually, she managed to collect over 500 signatures from students and citizens. - Zaskia campaigned to gain public support every Sunday at Bungkul Park, Surabaya. Copyright: Ecoton. After collecting signatures, Zaskia requested a hearing with the governor, to whom she wished to hand over the love letter with her demand for a better and healthier environment. The letter included her concerns with regard to the compliance of industries to wastewater discharge standards. The governor responded and appointed his representative to meet and accept the love letter. Touched by the love letter, the Governor promised to improve the monitoring and control mechanism of industrial pollution and made the rehabilitation of the Brantas river basin a priority in the East Java province. Pollution in the Brantas basin Brantas is the second biggest river basin on Java Island, Indonesia. The river flows along 17 municipalities, covering 25% of East Java’s catchment. It supports irrigation to about 10,000 paddy fields, over 121 industries, 14 regional water supply enterprises (PDAM), and 10 major hydropower plants [1]. To support these economic and livelihood activities, the river basin was divided into two primary development areas, namely agricultural in the middle/upper area and industrial in the downstream area. In the downstream area, which covers Surabaya city and surrounding regions, industrial development occurs without adequate pollution control measures in place. This has led to the deterioration of water quality. The Surabaya River Pollution Control Action Plan Study (1999) stated that the carrying capacity of the Surabaya river was 65 tons of BOD/day, but that the total pollution load was as high as 330 tons of BOD/day, much higher than the carrying capacity. Industrial wastewater discharge from pulp, paper, and sugar cane factories is a key source of waste and lethal chemicals. Chemicals such as organochlorine pesticide [2], plastic [3], and brominated flame retardant [4] were all found in the downstream area of Surabaya. Water pollution significantly affects the biodiversity of aquatic life, as well as the health and economy of communities living in the Brantas river basin. The decrease of high value fish species and decrease in general fish population has impacted the income of local fishermen. According to a 2011 study by Ecoton, about 50 fish species were lost in the past five decades. Industries often do not comply with discharge standards or other requirements. In particular, during the rainy season, when the water levels of the river are at their peak, industries simultaneously discharge untreated or poorly treated wastewater into the river. In addition, hidden channels continue to discharge untreated or poorly treated wastewater all year round. Other noteworthy violations include the fact that industries are not sending their mandatory six-monthly reports to the Environmental Protection Agency (EPA). Environmental management and water programmes in the Brantas basin The Ministry of Environment and Forestry (MEF) [5] of Indonesia has led two national programmes to tackle the problem of wastewater pollution. The Kali Bersih–PROKASIH aimed at reducing water pollution at the source. During the programme period of 2003–2008, 341 companies signed a statement letter in which they agreed to undertake measures to reduce pollution. Another programme called PROPER (Corporate Performance Rating Assessment) encouraged compliance of companies by publicizing information related to their management of the environment. This programme was less successful since many industries did not comply. Currently, Water Patrol is an ongoing joint programme which helps monitor and control water pollution, particularly industrial wastewater in the Brantas river basin. The programme involves a number of government agencies including the river basin organizations BBWS, Jasa Tirta 1, the EPA, the police department, the city government, the public work agency, and other related agencies. The Water Patrol programme is considered a success story since many different stakeholders are involved in controlling and monitoring industrial wastewater discharge. Despite the ongoing Water Patrol programme, industries continue to clandestinely discharge untreated wastewater. This raises key integrity concerns and highlights the institutional gaps that hamper programmes such as Water Patrol from performing to their full potential. Based on the experience of Ecoton, three key concerns require due attention. Recommendations to promote integrity and tackle wastewater pollution: building institutional capacity: environmental and river basin organisations Firstly, there is a need to build the capacity of EPA Officials, since providing the right leadership within the EPA is crucial. Many times, EPA staff members are nominated by the government and lack the right skills to lead the agency. Posts in the EPA are often considered comfort postings. The leadership does not want to take critical measures that involve risks and conflicts. There have also been instances where staff members have been eager to develop better and more effective programmes to counter pollution or pursue a case but were hampered due to a lack of support from the top. An additional limitation is that the EPA lacks a state investigator and has no real authority to investigate pollution. The EPA is understaffed and often dependent on the regional EPA or MEF. With no state investigator, industries can easily hide evidence, which hampers transparency and accountability. Preventing malpractice and promoting integrity management Secondly, it is key to reduce the opportunities for malpractice. During a private conversation, factory owners and managers told Ecoton that unscrupulous police officers offered to dilute the charges against the defaulters in water pollution lawsuits, provided they were handed additional cash or gifts. The cost of handling lawsuits is much higher as a result of corruption and blackmailing, than building or improving wastewater treatment facilities. In another case, police officers used complaint reports from NGOs to blackmail factory owners. One way of reducing chances of malpractice is to involve the media: publishing stories in which industrial violators may be revealed, thanks to photo and data evidence. Alternatively, complaint letters may be sent to the provincial and municipal EPA, with proof of the violations. Factory owners can be sensitive to bad publicity and may be willing to better abide by the laws. Integrity management, which focuses on integrity risk prevention, is also an important tool to reduce opportunities for malpractice. Together with cewas, WIN launched a pilot project applying the River Basin Integrity Management (IM) toolbox with the Brantas river basin organization in 2015. The initiative is a new collaborative and practical avenue for stakeholders to approach the subject of water quality and pollution in the basin. It should be explored further. Supporting community involvement Finally, an efficient response mechanism and more community involvement are required. Communities are too often left out of project planning and not involved in project monitoring yet they are the most directly affected and concerned by water pollution and water resource management in the basin. Communities and government institutions have noted the often slow response from EPA to their complaints and grievances. Slow responses have made many informants and communities feel neglected and discredited by the EPA. It’s important that faster and more efficient response mechanisms for complaints are built to ensure outreach to communities. The lack of awareness and participation in projects by communities is mainly due to a lack of information and access to active engagement in river basin management. Communities feel left out of river management planning. Most of the programmes are planned top-down and aren’t developed based on community needs. An example of this is a programme aimed at reducing open defecation in the river. The government built communal sanitation facilities but many of these were not used because they were not placed in suitable locations, were designed poorly, or were not maintained. The facilities did not meet the community's needs. Involving communities from the very beginning of the planning stage is crucial. It means plans will be developed from and for the community and allows them to build a sense of belonging in relation to the programme. This helps ensure sustainability. Communities also have a crucial role to play in monitoring programmes and holding governments and industries to account. The love letters of Zaskia Dwi Aridhiyant show that this is possible and can be effective but it requires follow-up and perseverance. Supporting the work of NGOs working with communities and of water integrity champions like Zaskia also for citizen monitoring is essential. ECOTON sees that children or young peoples are vulnerable victims of environmental degradation and especially water pollution. That’s why we focus on empowering them with information and skills to independently monitor water quality and build their confidence to take action to solve the problems. They can make a difference. - One of Zaskia’s group members handed the love letter to East Java Governor, Sukarwo. Copyright: Ecoton. About Ecoton ECOTON stands for Ecological Observation and Wetland Conservation. The organization is based in Wringinanom village, Gresik Regency. Established in 1998, ECOTON has been working on river rehabilitation issues for 19 years. Litigation and non-litigation are ECOTON’s basic approaches to increase multi-stakeholder awareness and participation in Brantas river conservation. The non-litigation approach consists of research, lobbying and advocacy, and education. ECOTON pursues litigation after non-litigation approaches have failed. Litigation is also used as an entry point to open discussions with government institutions or companies/industries. ECOTON works with youth to increase their awareness of the importance of their participation in ensuring the sustainability of clean water. ECOTON trained hundreds of students to monitor water quality with water bugs (biomonitoring). The method was developed 10 years ago to provide an easy and simple monitoring technique which enables everyone to actively participate in monitoring industrial or domestic pollution. [1] Ministry of Public Work. Water Resources Management Plan – Brantas River Basin. 2010. page 101 [2] Sudaryanto A, Takahashi S, and Tanabe S. Chapter 13: Persistent toxic Substances in the environment of Indonesia. Dev. In Environ Sci. 2007. 7: 587 – 627 [3] Darmawanti R. Estrogenic compounds analysis in Surabaya river sediment and their impact to Asian redtailed catfish (Hemibagrus nemurus) intersexuality. 2013. Thesis. Airlangga University. 104 pg [4] Ilyas M, Sudaryanto A, Setiawan I.E, Riyadi A.S., Isobe T, Takahashi S, Tanabe S. Characterization of PCB and BFR in sediments from riverine and coastal waters of Surabaya, Indonesia. Marine Poll Bull. 2011. 62:89-98 [5] The MEF shapes the national policy for industrial and domestic wastewater discharge. Other sector ministries (e.g. industry, marine affairs and fisheries) are responsible for implementing environmental management policy in their sector, while local governmental implementing are agencies responsible for issuing permits and monitoring discharge. Governors have the authority to control water pollution, but the implementation is in the hands of the head of Environmental Protection Agency (EPA).

This short documentary from Harare, Zimbabwe, shows how citizens took action to examine and question the way a loan meant for water service developments was used and administered. Local video journalist, Thomas Madhuku, interviews several residents from Mabvuku, a local township in Harare which is affected by a lack of water supply and speaks to the mayor of Harare to get his opinion on the matter. The video provides an inspiring example of water integrity in action! Do you also have interesting stories to share or need more information about the topic? Get in touch with us via info(AT)win-s.org

Last week, Transparency International published a resource guide on Monitoring Corruption and Anti-Corruption in the Sustainable Development Goals (SDGs). The publication stresses the important role of civil society organizations in monitoring corruption. It also points to major limitations in how the official SDG monitoring mechanisms take into account corruption and advocates mainstreaming reporting on corruption across the SDGs. Corruption is a factor limiting development processes and directly affecting how and if all the SDGs can be achieved, not only SDG16. It must therefore be taken into account across the board. To that end, the report provides guidelines to help identify potential indicators and data sources. Sample indicators are also provided for monitoring corruption for five key SDGs. Having had the privilege of contributing to the report, I am sharing a few thoughts on the role monitoring of corruption and integrity plays in supporting the achievement of the SDGs, especially that of SDG 6: Ensure access to clean water and sanitation for all. The importance of developing indicators to measure corruption for the SDGs Corruption is a concealed act by definition: there is not enough reliable data and evidence on the depth of the problem and its impact. As a consequence it is often not possible to monitor, and consequently control, corruption through an evidence-based approach. It is also not always possible to know what really works in fighting corruption, and if any progress has been made. But there are starting points. There are ways to gather reliable and actionable data to inform anti-corruption efforts. There are ways, to use better data, to raise awareness and develop the political will to effectively fight corruption. We can’t afford to wait for the next corruption scandal to come to the spotlight to get a sense of how costly and destructive corruption turns out to be, and how much harder it is to make our efforts to achieve SDGs. A sectoral focus on anti-corruption is required The most ubiquitously cited corruption indicators are those that attempt to describe the problem at a national level. Such indicators can be useful to raise awareness and prompt governments to act. However, their usefulness is limited when it comes to guiding decision-making for anti-corruption efforts. This is partly because many corruption risks tend to be sector-specific. For example, a major corruption risk area in the healthcare sector relates to financial contributions by pharmaceutical companies to medical research units to exercise undue influence. In the water sector, customers can be extorted to pay a bribe to receive a water connection or speed up repair work. As general corruption indicators lack the granularity to reveal such vulnerabilities peculiar to sectors, we need tailored indicators to be able to monitor risks and ensure corruption does not jeopardize the efficacy of global investments. Corruption indicators to monitor SDG 6 Weak governance, corruption, and lack of integrity directly threaten the fulfilment of the water SDG and by extension many of the other SDGs, as these are underpinned by water and sanitation issues. There is a role for stakeholders, and civil society in particular, to support the development of an SDG monitoring framework that addresses these risks. The water sector is particularly vulnerable to corruption, because of territorial and institutional fragmentation, the substantial funds involved in infrastructure projects, the marginalization of communities and local stakeholders, etc. There are also corruption and integrity risks at all levels in the sector and throughout project implementation: from policy and framework conditions all the way to service delivery and consumer interface. Indicators have to be able to grasp this diversity and still inform practical decision-making. So what makes a good indicator? How does one choose? The choice of sample indicators for SDG 6 for our report is partly driven by the availability of data, or at least the existence of experiences by various organizations in capturing data for the indicators. For example, a few of the sample indicators in the resource guide refer to water integrity indicators developed by the Good Governance Working Group of the Ugandan Ministry of Water and Environment with support from WIN and GIZ. These indicators are now being used to monitor good governance in the water and sanitation sub-sector in the country and could be adapted and mainstreamed in other countries. Other featured indicators have been tried and tested in multiple countries. For instance, data on non-revenue water is available and regularly updated for water utility companies in 133 countries. When selecting indicators, it is also important to strike a balance between direct and indirect (proxy) indicators. Whereas direct indicators can help gauge the prevalence and costs of corruption (e.g. petty corruption in service delivery), proxy indicators (e.g. procurement risks, participation levels) help unbox insights where direct corruption measurement is not possible, which, as mentioned, is often the case. Such bespoke indicators can point to red flags and possible enabling factors of corruption, and can thus be useful to guide anti-corruption interventions in the sector. We at WIN have been stepping up our efforts to develop corruption and integrity indicators for the water sector and to produce data on such indicators. We support organizations working on corruption, integrity and governance assessments and look forward to cooperating with others to develop strong indicator frameworks. Please don’t hesitate to get in touch to work together.