
What is water integrity?
Glossary of integrity and corruption in the water and sanitation sectors
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All Terms
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E-I
N-R
S-W
A
Accountability

Affordability
Anti-corruption
Audit
Accountability refers to the obligation of an individual or an organisation to accept responsibility for their activities, and to disclose them in a transparent manner. This includes the responsibility for decision-making, for handling money, or assets or other entrusted property.
Accountability is a principle of good governance in the water and sanitation sectors. It implies that individuals and organisations understand and fulfil their responsibility in managing resources sustainably and ensuring that everyone has access to adequate water and sanitation services, that they can demonstrate that they are carrying out their responsibilities, and that sanctions are possible where this is not happening.
Example
At the end of a budgetary year, senior managers of a water utility can be held accountable for achieving (or failing to achieve) the expected results for that period. Managers then have to present their work and results to the board of directors, other stakeholders or the public, and take responsibility for their decisions.
Affordability is a principle of the human rights to water and sanitation. It requires that the use of water and sanitation services is accessible at a price that is affordable to all people. Paying for these services must not limit people’s capacity to acquire other essential needs (for example food, housing, health, clothing, and education). The United Nations Development Programme suggests that water and sanitation costs should not exceed 3–5% of household income.
Anti-corruption in water and sanitation comprises all the actions aimed at combatting corruption for an organisation, programme, or sector. Just as corruption takes many forms, anti-corruption efforts vary in scope and in strategy. It can include preventive and reactive measures, including sanctions.
Example
Following some cases of collusion and bribery involving accounting staff and external contractors in the procurement of goods, a water sector organisation adopts an anti-corruption strategy to improve its organisational integrity, and prevent dishonest practices among its employees. Their plan combines awareness raising and training, integrity pacts, and digitalising its procurement process.
An audit is an objective, unbiased evaluation of an organisation’s compliance with either external requirements, such as laws and regulations, or internal requirements, such as guidelines, processes, or procedures. Audits can also be strategically used to assess risks.
Larger water service providers are likely to have their own compliance department to monitor regulatory changes that impact water and sanitation service provision, and regularly assess compliance through audits.
B
Bid rigging
Bribery

Bid rigging in the water and sanitation sector is a form of corruption where bidders agree to manipulate a bidding process. Bid rigging can take a variety of forms:
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Cover or complementary bidding, where bidders choose a winner and everyone but the winner deliberately bids above an agreed amount to establish the appearance that the winner’s quote is competitive
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Bid suppression, where a competitor agrees not to bid to ensure that the pre-agreed bidder will win the contract
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Bid withdrawal, where a bidder withdraws its winning bid so that an agreed competitor will be successful instead
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Bid rotation, where competitors agree to take turns at winning business, while monitoring their market shares to ensure they all have a pre-determined slice of the pie
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Non-conforming bids, where businesses deliberately include terms and conditions that they know will not be acceptable to the client
Example
A water utility needs to expand its water infrastructure services to a new residential area, so it advertises a call for proposals. Only two construction companies (bidders) submit offers (bids) for the project. One of the bidders submits an intentionally overpriced bid to ensure that the other bidder wins the contract in exchange for another favour.
Bribery is a corrupt practice by which money, services, or other valuables are offered to a person in a position of entrusted power to persuade them to do something in return, for example to get a contract, speed up a process, or get a favourable meter-reading. Bribery is widely criminalised, and both the party paying the bribe and the party receiving it may be held criminally responsible.
Example
A water utility manager offers money (a bribe) to a water regulator officer to receive preferential treatment and speed up the authorisation required for extracting water from a new underground water source.
The Kenya Anti-Corruption Commission carried out a household survey in 2011 showing that 17.8% of respondents reported having been asked by an official to pay a bribe in the last 12 months when accessing water and sanitation services.
C
Clientelism
Code of Conduct
Collusion
Corruption

Clientelism refers to the biased allocation of public resources, goods, and services (e.g. jobs, access to water, budget for water projects) to targeted individuals or groups for political or electoral support (e.g votes).
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Examples
Two weeks before the local government elections, an incumbent governor, who is also running for reelection and sits on the board of a municipality-owned water utility, signs a decree writing-off all customer debts from unpaid water bills to obtain their sympathy and votes.
A local politician offers an organisation a reduced water tariff or authorises an illegal water connection to the centralised network in exchange for campaign finance and political support.
A Code of Conduct is a document that outlines the principles and standards that all employees, partners, and third parties acting on behalf of an organisation must follow. Drawing on the organisation’s mission and values, a Code of Conduct details the organisation’s norms and rules, as well as the standard of integrity and compliance that is expected from every employee and member of the organisation, and a list of disciplinary sanctions that may result in the case of non-observance.
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Example
Following an estimated loss of over US$ 20 million in public resources to fraudulent and corrupt activities, the City of Stellenbosch in South Africa introduced an anti-corruption hotline tied to a Code of Conduct. The Code of Conduct spells out the specific responsibilities of staff at municipal entities, including the water utility, and what consequences may arise from violating the policy (including suspension, salary reductions, dismissal, or criminal proceedings).
Collusion refers to any fraudulent, generally secret, agreement between parties whereby one offers a bribe, gift or favour in exchange for another favour or preferential treatment. In the context of public procurement, collusion refers to cooperation between bidders to skew contracting to their benefit, for example through bid rigging.
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Example
Two consulting firms offering auditing services to public water utilities, fraudulently agree to raise the price of their services.
Corruption is the abuse of entrusted power for private gain or for consolidation of political power (e.g. to finance political parties). Entrusted power means not only power held by the government, but also power held by private actors and public-private organisations.
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In the water and sanitation sectors, corruption takes different forms, from bribery and extortion to the falsification of water bills and collusion in procurement. It can involve direct cash payments (bribes) or other types of exchange (for example sexual acts in the case of sexual corruption), as well as favours such as advancing the interests of family, friends, and political allies (nepotism). Overall, it increases costs, skews programmes, and weakens water and sanitation sector institutions.
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Corruption is often categorised in two types: petty and grand.
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Petty corruption involves either lower-level employees, small sums of money, or favours from users in exchange for service. Cumulatively, petty corruption is significant. It impacts the most vulnerable more severely.
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Grand corruption generally involves high-level politicians or executives and large sums of money. In water and sanitation it can lead to the loss of billions of dollars annually from major water and sanitation sector programmes.
Examples
Field technicians refuse to perform or delay performing maintenance works to domestic water connections unless they are paid bribes by customers.
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The Minister of Public Works and Infrastructure intervenes in a public procurement process to award a large-scale infrastructure project to a construction company that offered a large sum to the minister in exchange for winning the contract.
D
Debarment
Discretion / discretionary
Due diligence
Debarment (also called blacklisting) is a procedure by which an individual or an organisation is formally excluded from participating as a bidder in a procurement process, as a sanction for being found to be involved in fraud, mismanagement, corruption, or other similar dishonest practices.
Debarment lists are ideally shared across entities (within a sector, region, or among stakeholders like public development banks).
Example
The analysis of the bids for the purchase and installation of new water meters reveals unequivocally that two bidders colluded to win the contract. In response, the bidder, a water utility, debars the two companies and reports them to the regulator.
Discretion (or discretionary power, discretionary decisions) refers to an individual or group making decisions based on their own judgment, criteria, or preference, rather than being controlled by rules or procedures. Such decisions can often lead to corruption.
Example
In the absence of set tariffs or rules for the management of a small water system, a water committee chief might have discretionary power to decide who receives water and at what price, leaving the door open for favouritism or extortion.
Due diligence refers to the systematic collection and analysis of information to evaluate the trustworthiness and integrity of potential and current contractors.
E
Embezzlement
E-procurement
Extortion
Embezzlement is a crime that takes place when an individual entrusted with property, money, or another asset dishonestly and unlawfully appropriates that resource for their own personal use.
Examples
An employee working in the accounting department of a water utility transfers the salary of an employee who left the organisation several months ago to his/her personal bank account. An internal audit reveals the scheme, and the accountant is laid off and faces criminal charges for money embezzlement.
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The Three Gorges Dam in China extends over more than 2 km across the Yangtze River and its construction involved the largest resettlement in dam-building history, worth US$ 26 billion. However, US$ 7.1 million were embezzled, misappropriated, or illegally used, severely affecting the resettlement of displaced people.
E-Procurement, short for electronic procurement, is the process of requesting, ordering, and purchasing goods and services online. E-Procurement enables procurement staff to automate various activities, functions, and procedures, including policies, contracts, and contractor relationships.
Automation of the procurement process reduces human error and makes it easier to detect fraudulent manipulation by staff. In addition, its centralised transaction tracking and simplified reporting help to reduce delivery times and shorten procurement cycles.
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Example
Following some cases of collusion and bribery involving accounting staff and external contractors in the procurement of goods, a water sector organisation implements an e-procurement system to automate routine purchases, prevent human errors, and end dishonest practices in the acquisition of goods.
Extortion is a corrupt act committed by an individual who abuses their power, position, or knowledge to demand money or favours from others by making coercive threats.
Example
The operational staff of a water utility extort users by refusing to perform maintenance works on their domestic water connections unless they get money in return.
F
Fraud
Fraud is the intentional and false representation or hiding of facts for the purpose of gaining an unfair or illegal advantage, resulting in damage or loss to an organisation or individual.
Example
A consultant providing professional services to a water utility generates a fraudulent invoice including tasks and activities that were never performed, inflated timesheets, and fictitious payments.
G
Governance
Governance is a concept that goes beyond the traditional notion of government to focus on the relationships between leaders, public institutions, and citizens, including the processes by which they make and implement decisions. Good governance is characterised by participation, accountability, transparency, inclusiveness, respect for the rule of law, and anti-corruption.
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Governance involves negotiations around water management and distribution, with fundamental implications for power relations: who controls water and sanitation services, who receives access to water and sanitation services, how and when they receive it, and at what price.
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The term can also be applied to organisations, companies, and NGOs, in which case it is also referred to as corporate governance. In water sector organisations and water utilities, governance refers to the set of policies, rules, practices, and processes used to direct the organisation and the relationships among its board, management, staff, and stakeholders, including setting long-term goals and objectives as well as determining the intended culture and its ethical standards, while ensuring regulatory compliance and accountability.
H
Human rights to water and sanitation
The human rights to water and sanitation were first recognised in July 2010, by the United Nations General Assembly. Resolution A/64/262 “recognized the right to safe and clean drinking water and sanitation as a human right that is essential for the full enjoyment of life and all human rights”.
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The human right to water entitles everyone to have access to sufficient, safe, acceptable, physically accessible, and affordable water for personal and domestic use. The human right to sanitation entitles everyone to have physical and affordable access to sanitation, in all spheres of life, that is safe, hygienic, secure, and socially and culturally acceptable and that provides privacy and ensures dignity.
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Many countries have enshrined the human rights to water and sanitation in their national constitutions. They must then ensure that legal, policy, and regulatory frameworks are in place to make water available, safe, accessible, affordable, and acceptable (this is relevant for areas that are still underserved as well as for self-supply).
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Human rights and integrity are complementary frameworks. Fundamental principles such as transparency, active and meaningful participation, and accountability are also critical for the fulfilment of human rights.
Example
A human rights’ advocacy group provides judicial representation to residents of a particular informal settlement excluded from access to water and sanitation services. The proceedings are brought before the Constitutional Court to hold the local government and the water utility responsible for failing to provide residents with access to sufficient and safe water for personal and domestic use.
I
Informal water provider

Integrity
Integrity failure
Integrity management
Integrity Pact
Integrity risk
Integrity tool
An informal water provider is defined as any individual or organisation operating outside the legal and regulatory framework that supplies water to end users without having the official public authorisation, licence, or permit to do so. These providers typically operate in areas with precarious or no water infrastructure, such as low-income urban neighbourhoods, informal settlements, or poor rural areas.
Informal water providers often rely on different sources of water, such as their own piped connections or boreholes, and sell it using water tankers, pushcarts, jerrycans, or buckets (Kjellén and McGranahan, 2006).
Informal water providers play a crucial role in the provision of water and sanitation services in many cities around the world. Up to 25% of urban populations in Latin America and almost 50% of urban residents in Africa rely to some extent on small-scale informal water providers.
Informal water service provision often comes with high integrity risks.
Example
In Nairobi, Kenya, informal water providers supply water to households in many informal settlements, by selling 10-litre jerrycans, which are filled with water from their own domestic water connection or boreholes, from formal service points controlled by force, or from illegal connections. The price of water can be up to 20 times higher than from a formal water connection.
Water integrity is the use of vested powers and resources ethically and honestly for the provision of sustainable and equitable water and sanitation services. It requires that holders of public or private office do not place themselves under any financial or other obligation to individuals or organisations that may influence their ability to perform their duties.
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Integrity is implicit in human rights obligations, explicit in the administrative justice laws of many countries, and practically operationalised through transparency, accountability, participation, and anti-corruption.
Example
The project manager of a water utility is responsible for managing a large-scale infrastructure contract. During the procurement process, a construction company interested in being awarded the contract offers the project manager a generous bribe in order to win the bidding process. The project manager rejects the bribe and denounces the construction company to the water regulator. The project manager decided to act with integrity.
Integrity failures can be defined as instances in which integrity has broken down or been violated. These may include illegal activities, or activities which are legal but not moral or just.
Example
Cutting water to poor households in an emergency like the COVID-19 pandemic; failing to implement legislative or constitutional obligations to guarantee the human rights to water and sanitation; and not acting to upgrade water and sanitation services in informal settlements all constitute failures of integrity.
Integrity management is a change management approach for improving integrity in an organisation’s governance and operations (for example across human resources, procurement, operations and maintenance, financial management, etc.).
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Integrity management relies on the identification of integrity risks. It aims to reduce losses from corruption and bad practices, and reduce reputational risks.
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Integrity management includes elements of countering corruption and adhering to rules but goes beyond this, to include cultivating a culture of integrity and applying high ethical standards to organisational processes and activities.
Example
In Bangladesh, the water utility of Khulna city, Khulna Water and Sewerage Authority, has launched an integrity management process using integrity tools. The process has involved regularly identifying critical integrity risks for the organisations and best approaches to mitigate these.
An Integrity Pact is a ‘collaborative mechanism in which public contracting authorities and bidders sign a public agreement committing to refrain from corruption and enhance transparency and accountability in a public contracting project. As part of the agreement, an independent civil society organisation monitors compliance with applicable laws and regulations, provides recommendations to mitigate corruption risks and foster good governance, and informs the public throughout the whole process’.
Example
Since 2002, Transparency International has supported Mexico to monitor and oversee the transparency and integrity of public contracting processes for large-scale hydroelectric infrastructure projects. High-level Mexican government authorities instructed the Federal Electricity Commission to work together with Transparency International in the implementation of Integrity Pacts, including the intervention of social witness groups for monitoring and evaluating projects’ execution. The success of Integrity Pacts in improving transparency and preventing corruption in large-scale infrastructure projects led to a new law ordering mandatory Integrity Pacts and the intervention of Social Witness groups in all public contracts with a value over a certain threshold.
Integrity risks are conditions (e.g. limited capacity) or processes (e.g. flawed standard operating procedures) that will negatively affect the capacity of organisations to fulfil their mandates with integrity and that compromise sustainable water and sanitation service provision. Integrity risks have a known (or estimated) probability of occurrence.
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Integrity risks exist at different scales: from individual actions such as accepting bribes for service delivery and maintenance, to collusion in big infrastructure projects involving powerful groups.
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Integrity risks can also take many forms in any of the operational areas of an organisation or different business and sector processes – from contract awards and budget allocation to meter readings and maintenance.
Example
An internal audit reveals that a water utility is subject to integrity risks because it does not have the adequate internal controls in place to prevent accounting fraud. Following the recommendation of the auditors, the water utility is adopting a computerised accounting system.
Integrity tools are standards, management processes, and operating procedures that can be implemented by organisations to identify, analyse, prevent, avoid, minimise, and mitigate integrity risks.
Example
Detailed job description is an integrity tool to prevent favouritism and nepotism in recruitment processes. Integrity pacts are integrity tools aimed at preventing corruption and collusion in procurement processes. A Code of Conduct is a typical integrity tool to set standards of behaviour and prevent misconduct and wrongdoing among employees and staff.
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When a water utility finds that some of its staff have been involved in cases of water theft, different integrity tools (measures or actions) can be implemented, such as Anti-Corruption Measures, Staff Rotation, or Integrity and Compliance Training, to prevent the risk’s occurrence.
N
Negligence
Nepotism

Non-Revenue Water (NRW)
Negligence is a failure to exercise appropriate or ethical care under specific circumstances, or a failure to take into consideration the potential harm that they might foreseeably cause to other people or property. It can be an integrity failure.
Nepotism is the act of abusing one’s power or official position to offer a job or a position to a close contact while disregarding their merit and qualification. It is a form of favouritism shown to acquaintances and family members.
Example
A water utility is publicly owned and controlled. The newly elected ruling coalition overstaffs public utilities to pay for electoral favours. Unions are very strong and generally well connected politically. Accordingly, downsizing is a difficult task because of strong union opposition and explicit or implicit political support. Overstaffing results in low productivity and low staff morale.
Non-Revenue Water (NRW) is water that is distributed through the centralised network but is lost before it reaches the customer. NRW can be caused by physical losses from leaking or broken pipes, and by losses resulting from metering inaccuracies, data errors, illegal connections, and water theft.
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High levels of NRW are detrimental to the financial viability of water utilities.
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P
Participation
Patronage
Participation implies that all stakeholders, including marginalised and resource-poor groups, are meaningfully involved in deciding how water is used, protected, managed, and allocated, as well as how sanitation services are provided.
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Example
A water utility is responsible for distributing water in an informal settlement where infrastructure is very precarious. Together with the local government, the water utility trains residents to install communal water sinks, toilets, and sanitation facilities. The community actively participates in the management of the shared infrastructure and co-manages water resources to distribute them equitably among the residents according to their needs. This participatory approach contributes to the legitimacy and ownership of solutions adopted within the community.
Patronage is a form of favouritism in which a person is selected, regardless of qualifications or entitlement, for a public sector job or benefit because of political affiliations or personal connections (see also nepotism).
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Example
The newly elected city mayor, who will also be sitting on the board of directors of the public water utility, finds a good opportunity for patronage distribution by appointing his friend and closest political advisor as the Head of the Communications Department of the utility, although the friend does not have prior experience in communications or the water sector.
R
Reconciliation of accounts
Red flag
Regulatory capture
Revolving door
Reconciliation of accounts is an internal process by which the integrity of an accounting system is verified to detect and prevent embezzlement, misappropriation, and misuse of financial resources of an organisation. This internal control mechanism is established to confirm that the internal monetary records of an organisation align with the records of the bank used by the organisation for incoming and outgoing payments.
Example
Every month, the accounting department of a water utility undertakes a reconciliation of accounts by cross-checking its internal accounting records with those from the bank to verify that incoming and outgoing money transactions are identical. The procedure reveals that in the last three consecutive months, pay checks amounting to US$ 10,000 have been transferred to an unknown account. An investigation is initiated to identify who is responsible for fraudulently transferring money to a personal account.
Red flags are indicators of potential issues such as governance or integrity failures, collusion, or corruption within an organisation, workplace, or project. It must be noted, however, that the presence of red flags should not necessarily be treated as evidence of corrupt activities. Rather, red flags should be observed and further probed or investigated for potential incidences of corruption.
Example
The Framework for Integrity in Infrastructure Planning is (FIIP) is a tool to detect red flags in the early phases of water infrastructure development. It includes a series of indicators related to the purpose and beneficiaries of the investment, the type and scale of the investment, and the planning process.
Regulatory capture occurs when a regulator is dominated and controlled by the commercial interests of the industries it is mandated with regulating. The result is that, instead of acting in the public interest, the regulator acts in ways that benefit the companies and organisations it is supposed to be regulating.
Example
Water-intensive industries such as hydroelectric power generation and large-scale agriculture lobby and improperly influence the water regulating agency in a country to pass regulations favourable to them and to ease their regulatory burden, to the detriment of residential customers and small farmers. (See also state capture.)
Revolving doors refers to the movement of individuals between positions of public office, such as regulators or agencies, and private sector jobs in the same sector. If not properly regulated, this can lead to conflict of interest and open the door to abuse.
A cooling-off period is the minimum time required between switching from the public to the private sector, intended to discourage the practice and minimise its impact.
Example
The former director of the water regulating agency joins the largest water utility in the country as a member of the board. A few months later, an investigation reveals that prior to joining the utility’s board, and while still acting as director of the regulating agency, she leaked confidential and privileged information to the water utility, favouring the utility’s market position and resulting in an unfair competitive advantage. This revolving-door case involves the misuse of privileged information and a clear conflict of interest.
S
Service Charter
Sexual corruption (sextortion)
State capture
A Service Charter is a document that outlines how an organisation promises to work with its customers and how it operates. It informs the customers about the practices of the organisation and the services it provides, thus functioning to establish a good relationship with customers and increase the reliability of the services offered.
Example
The Water Service Regulatory Board's (WASREB) service charter is a statement of the organisation's commitment to water users. The charter defines the manner in which WASREB intends to relate to users, the services they should expect from WASREB, the manner in which these services will be delivered, and the options for recourse in the event of inadequacy.
Sexual corruption (also referred to as sextortion) is a form of sexual exploitation and corruption that occurs when people in positions of authority engage or extort sexual acts in exchange for something within their power to grant or withhold. In effect, sexual corruption is a form of corruption in which sex rather than money is the currency of the bribe.
Example
In Nairobi, cases of water vendors taking advantage of the socio-economic vulnerabilities of women and girls to coerce them into sex in exchange for access to water and/or sanitation services are common knowledge for many living in informal settlements. The local jargon for sextortion is water for water. KEWASNET and ANEW have done research on the issue and supported the development of a bill to criminalise the practice.
State capture refers to the situation where powerful individuals, organisations, companies, or groups within or outside a country use corruption to shape a nation’s policies, legal environment, and economy to benefit their own private interests. (See also regulatory capture.)
T
TAPA

Transparency
TAPA stands for Transparency, Accountability, Participation, and Anti-corruption. It is a four-pillar framework developed by the Water Integrity Network (WIN) to advance integrity in the water sector. It is premised on the notion that implementing transparency, accountability, participation, and anti-corruption measures in organisations and across the water and sanitation sectors is a practical way to increase integrity and reduce corruption.
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In the water and sanitation sectors, this could include:
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Transparency measures could include: disclosure rules, transparency on tariffs, strong right-to-information laws
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Accountability measures could include: clear responsibilities, auditing rules, social accountability mechanisms like citizen report cards or public expenditure tracking, support to media, grievance mechanisms
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Participation measures could include: public consultations and hearings, civil society access to decision-making instances, boards and meetings
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Anti-corruption measures could include: recording conflicts of interests, protecting whistleblowers, strict debarment and due diligence rules.
Transparency means that everyone has access to relevant information, including information about budgets, plans, and implementation progress, in a manner that is easily accessible and understandable. Transparency is a prerequisite for meaningful participation and accountability.
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Example
A local government adopts measures to make all documentation related to the public budget available on the local government website in accessible language and open formats. This includes information on budget design, implementation, and expenditure. This makes it possible for citizens to hold government accountable.
W
Water cartel /
water syndicate / water mafia
Water theft
Whistleblower
A water cartel (or water mafia or water syndicate) is a fraudulent organisation which exerts partial or total control of water supply services in a particular area in order to sell water to users for its private gain. Cartel behaviour includes seizing water infrastructure, charging abusive prices, and reducing water supply. Water cartels might also provide sanitation services, such as when they seize and control public bathrooms and toilets serving a community.
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Members of water cartels may include owners of water points, as well as the owners of pushcarts used to transport water to households, and legal or illegal landlords or landowners. In some contexts of pronounced informality, water cartels have been found to have links with politicians and public authorities, who turn a blind eye to their illegal activities in exchange for bribes or political support.
Example
In Mukuru, an informal settlement in the city of Nairobi, Kenya, powerful water cartels seize public water kiosks installed by the water provider to supply services to the community. The cartel reduces water supply deliberately by vandalising water pipes to create scarcity and increase the price of water for their own profit.
Water theft is any taking of water in violation of existing regulations. Such violations can include not paying the amount specified by local water regulations, tampering with water meters, tapping boreholes without necessary licenses, or installing unauthorised connections to the water network.
A whistleblower is an individual who reports or exposes wrongdoing within a private or public company or government organisation to his superior, the public, or the authorities. Whistleblowers are often employees of the organisation who have become aware of some wrongdoing while performing their job duties, but they may also be contractors, customers, or anyone else who witnesses or becomes aware of illegal activities within an organisation. Whistleblowers require protection from those they expose.
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Whistleblower protection refers to the measures taken to shield an informant from retaliation. Whistleblowing policies that describe the role of whistleblowers and the protections they are entitled to, are an important integrity tool for water service providers and sector institutions.
Example
An employee of a water utility noticed that the acid and chemicals used for cleaning the filters of a wastewater treatment plant were dumped back into the drinking water supply system. The employee alerted her superiors, who did nothing and ordered her to remain quiet about the incident. Lacking internal reporting mechanisms, the employee acted as a whistleblower by reporting the actions to the local newspaper, which resulted in a formal investigation against the water utility led by the regulatory agency.