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Event | Date
Adoption of APM/Start of audit | 28.4.2015
Official sending of draft report to Commission (or other auditee) | 15.3.2016
Adoption of the final report after the adversarial procedure | 10.5.2016
Commission’s (or other auditee’s) official replies received in all languages | 2.6.2016

EN
2016

NO 15

Special Report

Did the Commission
effectively manage
the Humanitarian aid
provided to populations
affected by conflicts
in the African Great Lakes
Region?

(pursuant to Article 287(4), second subparagraph, TFEU)

Audit team

The ECA’s special reports set out the results of its performance and compliance audits of specific budgetary areas or management topics. The ECA selects and designs these audit tasks to be of maximum impact by considering the risks to performance or compliance, the level of income or spending involved, forthcoming developments and political and public interest.

This performance audit was produced by Chamber III of the ECA, which is responsible for the audit of the external actions’ spending areas. Mr Karel Pinxten, Dean of this Chamber, is the reporting Member. He was supported in the preparation of the report by the Head of his office, Gerard Madden; Gérald Locatelli and Beatrix Lesiewicz, support and quality control; Myriam Cazzaniga, Head of Task; Kim Hublé, Peter Kovacs, Cyril Messein and Roberto Ruiz Ruiz, auditors.

From left to right: C. Messein, M. Cazzaniga, K. Pinxten, K. Hublé, R. Ruiz Ruiz.

Contents

Acronyms and abbreviations

Executive summary

Introduction

Audit scope and approach

Observations

Funding allocated to well established main priorities but insufficient clarity at further prioritisation stage

The Commission has properly identified needs for the AGL region

The Commission’s response is appropriate

Insufficient transparency at the project selection stage

Overall, the Commission’s monitoring is appropriate although the information obtained could be better used

In most cases, the Commission obtains adequate information on project implementation

Follow-up is insufficient

Most of the projects examined delivered satisfactory results

Overall outcomes achieved are positive but in some cases, the Commission’s assessment is not clearly justified

The Commission was responsive to changes but could better justify time extensions granted

There is limited evidence of what is being done to link Relief, Rehabilitation and Development

Conclusions and recommendations

Annex I | — | Map of the African Great Lakes Region
Annex II | — | DRC refugees at the beginning of 2016
Annex III | — | Map Burundian refugees at 26 January 2016
Annex IV | — | List of projects examined
Annex V | — | Interim and final reports examined
Annex VI | — | Amendments to projects reviewed

Reply of the Commission

Acronyms and abbreviations

AGL: African Great Lakes

DG International Cooperation and Development: Directorate-General for International Cooperation and Development

DG ECHO: Directorate-General for Humanitarian Aid and Civil Protection

DRC: Democratic Republic of the Congo

EAR: Emergency Aid Reserve

EDF: European Development Fund

EEAS: European External Action Service

HAP: Humanitarian Action Plan

HIP: Humanitarian Implementation Plan

IDP: Internally Displaced People

IHL: International Humanitarian Law

IO: International organisation

LRRD: Linking Relief and Rehabilitation with Development

NFI: Non Food Items

NGO: Non-governmental organisation

NIP: National Indicative Programme

OCHA: Office for the Coordination of Humanitarian Affairs (UN agency)

Executive summary

I

The African Great Lakes area has in recent decades been beset by conflicts, which have resulted in huge population displacements with severe humanitarian consequences. The Commission has funded humanitarian projects in this area since 1994, and is continuing with its efforts to tackle the consequences of the conflicts and unrest.

II

At present, the area most affected is the Democratic Republic of the Congo, which has about 1.6 million internally displaced people. Currently, there are about 437 000 Congolese refugees in the neighbouring countries, mainly in Burundi, Rwanda, Uganda and Tanzania. The unrest in Burundi in 2015 has added about 236 000 to the overall figure for refugees. In addition to the refugees and the displaced persons, humanitarian aid is also given to the local populations who are caught up in the conflicts or are hosting refugees and displaced persons.

III

This aid consists of the provision of shelter, food, health care and other basic services. To provide this aid the Commission works in close cooperation with international non-governmental organisations, United Nations agencies and other international organisations. The amount spent on humanitarian assistance in the African Great Lakes area over the period 2011-2015 was about 300 million euros.

IV

The auditors conclude that humanitarian aid to the population affected by conflict, in the African Great Lakes area was, generally, managed effectively by the Commission. The needs assessment carried out was comprehensive and the flexibility to react quickly to changing circumstances was ensured. Most of the projects examined were satisfactory in responding to the particular challenges faced. However, a number of weaknesses were identified.

V

There was a lack of documentary evidence at the stages of determining geographical priorities and assessing project proposals. As a result it was not possible to determine whether the projects chosen complied with the relevant criteria and if the most appropriate projects were selected. When considering the merits of proposals their cost efficiency was not given sufficient attention.

VI

The monitoring framework was appropriate given the difficult working environment. The reports from the partners were, however, frequently late and this hampered their usefulness. The expertise of the Commission’s field staff was helpful to the funded partners but reporting from the field visits was not sufficiently comprehensive. Because of inadequate recording of the follow-up of problems raised, it was not possible to ensure that these were satisfactorily resolved. On a more global level there is no reporting on the Humanitarian Implementation Plan (HIP) to provide an overview of results and lessons learnt.

VII

The results achieved overall for the projects examined were satisfactory. One partner, however, managed to spend most of its budget despite achieving a small percentage of the planned results. In a few cases the justification for time extensions and additional budgets was not apparent. As regards the Commission’s own assessment of results it was unclear, in some cases, from the information available, how they arrived at their conclusions.

VIII

While the desirability of Linking Relief, Rehabilitation and Development (LRRD) has been widely accepted by the Commission and other donors, there are very few examples of this being applied in practice. Without very actively pursuing this goal there is a danger that opportunities to move from humanitarian aid to development aid will be missed.

IX

A number of recommendations are made in paragraphs 58 to 63 of the report which are designed to enable the Commission to improve its management of humanitarian aid in the Great Lakes area and beyond.

Introduction

01

The African Great Lakes (AGL) region comprises the countries of Burundi, Democratic Republic of the Congo (DRC), Kenya, Rwanda, Tanzania and Uganda (see map in Annex I). It has witnessed some of the worst conflicts on the African continent over the last decades. In Eastern Congo, armed groups, including the Congolese Army, continue to commit human rights abuse, exactions, looting accompanied by violence like rape, abduction, and forced recruitment of children. The resulting humanitarian crisis in the Democratic Republic of the Congo (DRC) is among the world’s most complex and protracted emergencies in one of the world’s poorest countries¹. At the end of April 2015, presidential elections in Burundi, that took place in July, triggered a spiral of violence and unrest that sent hundreds of thousands on the roads fleeing their country.

02

Towards the end of 2015, there were about 1.6 million Internally Displaced People (IDPs) in the DRC and more than 437 000 Congolese refugees (see Annex II) in the neighbouring countries, namely in Burundi, Rwanda, Uganda and Tanzania. At the end of January 2016, 236 000 Burundians have fled their country and are now mostly hosted in refugee camps in Rwanda and Tanzania (see Annex III about the number of Burundian refugees per country of the region).

Picture 1

Internally Displaced People (IDP) settlement of Kibabi - Kishusha, Masisi, North Kivu (6 360 people at the end of August 2015)

Source: European Court of Auditors.

03

Article 214 of the Treaty of on the functioning of the EU underpins the commitment of the EU to provide humanitarian aid consisting of assistance, relief and protection to victims of natural and man-made disasters around the world. The overall policy framework for humanitarian assistance is outlined in the ‘European Consensus on Humanitarian Aid’ of 2008². This political document sets out the EU’s vision based on common principles aiming at improving the coherence, effectiveness and quality of its humanitarian response.

04

The principal objectives (see Box 1) and provisions for the implementation and administration of humanitarian aid by the Commission are laid out in the Humanitarian Aid Regulation of 1996³. Its assistance targets the most vulnerable populations and is based on the humanitarian principles of humanity, neutrality, impartiality and independence. It also provides support for the defence of humanitarian work and the respect of humanitarian principles and international humanitarian law (IHL).

Box 1

Principal objectives of the Union’s humanitarian aid⁴:

(a)to save and preserve life during emergencies and their immediate aftermath and natural disasters that have entailed major loss of life, physical, psychological or social suffering or material damage;

(b)to provide the necessary assistance and relief to people affected by longer-lasting crises arising, (…) especially where their own governments prove unable to help or there is a vacuum of power;

(c)to help finance the transport of aid and efforts to ensure that it is accessible to those for whom it is intended (…);

(d)to carry out short-term rehabilitation and reconstruction work, (…) taking long-term development objectives into account where possible;

(e)to cope with the consequences of population movements (refugees, displaced people and returnees) caused by natural and man-made disasters and carry out schemes to assist repatriation (…);

(f)to ensure preparedness for risks of natural disasters or comparable exceptional circumstances and use a suitable rapid early-warning and intervention system;

(g)to support civil operations to protect the victims of fighting or comparable emergencies, in accordance with current international agreements.

05

For the AGL region, the initial budget⁵ allocated by the Commission for humanitarian aid ranged between 52 million euros in 2011 and 47 million euros in 2015. The amount spent after receiving the top-up funding from the EU Emergency Aid Reserve (EAR)⁶ or from the European Development Fund (EDF)⁷ reached, on average, 63 million euros annually (see Graph 1). In addition to these amounts, the Commission spent, annually, about 1.8 million euros for its field office in the DRC and 7 million euros for aerial transport in the AGL region⁸.

06

As a humanitarian aid donor, the Commission’s worldwide funding is channelled through about 200 partners⁹ with whom they have signed a framework partnership agreement (FPA)¹⁰ for a duration of 4 to 5 years. These partners are international non-governmental organisations (NGOs), international organisations (IOs)¹¹ or agencies from the United Nations (UN). In the AGL region, the split was: 46 % NGOs, 7.3 % IOs and 46.7 % UN. Given the specificities of humanitarian aid, the projects funded last between a couple of months and 18 months.

07

Annually the Commission decides on the allocation of the initial budgetary envelope for humanitarian aid in a worldwide decision. The proposed responses per crisis, country or region as well as the corresponding budget are detailed in the Humanitarian Implementation Plans (HIP) and Technical Annex (including operational recommendations), established on the basis of a needs assessment. The HIP serves as terms of reference for the partners when preparing their requests for funding.

08

In the case of the AGL region, there is a major assessment (or selection exercise) of funding requests received, at the beginning of the year. Additional assessments may take place in the course of the year according to the evolution of the situation. The selected projects have a duration of between 3 and 12 months. This may be extended by up to 6 months, to a maximum of 18 months in total.

Graph 1

Repartition of the HIP allocation per main areas for the period 2011-2015

Source: European Court of Auditors.

09

A key feature of the Commission’s interventions is its presence in the field. It has put in place an extensive field network with offices located in crisis zones where EU-funded relief aid is being delivered¹². The main functions of this network are:

(a)to provide headquarters in Brussels with up-to-date information and analysis on needs for a given country, region or crisis;

(b)to contribute to the development of humanitarian intervention strategies;

(c)to give technical support to EU-funded humanitarian operations;

(d)to monitor the implementation of EU-funded projects;

(e)to facilitate donor coordination at field level.

10

In the DRC, the field network is comprised of the head office in Kinshasa, one country sub office in Goma and an antenna in Bukavu. It has five expatriated experts (‘Technical assistants’) and 12 local staff (‘National staff’). In addition, several sectoral experts (food, protection, health …) based in the regional support office in Nairobi (Kenya) contribute as needed to the selection, monitoring and assessment of projects in the African Great Lakes region¹³.

1It is ranked 176th, out of 188, in the world on the UNDP Human Development Index for 2014. Burundi is 184th, Rwanda and Uganda are 163th and Tanzania is 151th.

2Joint Statement by the Council and the Representatives of the Governments of the Member States meeting within the Council, the European Parliament and the European Commission (OJ C 25, 30.1.2008, p. 1).

3Council Regulation (EC) No 1257/96 of 20 June 1996 concerning humanitarian aid (OJ L 163, 2.7.1996, p. 1).

4Article 2 of Council Regulation (EC) No 1257/96.

5From Chapter 23 02, humanitarian aid, food aid and disaster preparation, section 3 of the general budget of the EU.

6The EAR is designed to enable a rapid response to specific aid requirements for non-EU countries that were unforeseeable when the budget was drawn up. Priority is given to humanitarian operations, but the reserve may also be used for civil crisis management and protection if necessary. Decisions on its use are taken by the Council and the European Parliament, on a proposal from the Commission.

7A reserve of 204 million euros, approximately 0.7 % of the total 11th EDF, for the period 2014-2020, is set aside in order to finance humanitarian and emergency operations in ACP countries only in cases of unforeseen needs which cannot be covered by funds planned in ECHO’s programme. ECHO is in charge of administering this reserve and may be using the funds after having received the EEAS and DG International Cooperation and Development’s agreement.

8The total amount of the contract is higher. This is because ECHO Flight also flies in other countries outside the AGL region such as Mali, Kenya, Chad, on an ad hoc basis.

9International NGOs are selected through a specific procedure carried out by DG ECHO. IOs and UN agencies have to undergo an assessment as requested in Article 60 of the Regulation (EU, Euratom) No 966/2012 of the European Parliament and the Council of 25 October 2012 on the financial rules applicable to the general budget of the Union and repealing Council Regulation (EC, Euratom) No 1605/2002 (OJ L 298, 26.10.2012, p. 1).

10A Financial and Administrative Framework Agreement (FAFA) with UN agencies.

11International Committee of the Red Cross, International Federation of the Red Cross and the International Organisation for Migration.

12Beginning of 2016, there were 48 field offices in 40 countries and 12 regional offices.

13Sectorial experts providing support to country offices are located in regional offices. From mid-2015, Kinshasa becomes a regional office providing support to the Republic of Congo, Angola, Burundi, Rwanda and Tanzania.

Audit scope and approach

11

We examined whether the Commission effectively managed its funding for humanitarian aid targeted at populations affected by conflicts in the African Great Lakes region. Our audit focused on the following three main questions:

(a)Did the Commission allocate its funding to well-established priorities?

(b)Did the Commission monitor the projects properly?

(c)Did the projects achieve their objectives?

12

The audit covered the Commission’s support during the period 2011-2015 to the AGL region consisting of the DRC, Uganda¹⁴, Rwanda, Burundi and Tanzania. It was carried out between May and December 2015 and included the following:

(a)A review of EU policy documents and strategy documents related to humanitarian aid, and other relevant documentation and reports.

(b)Interviews with Commission officials and with partners’ representatives.

(c)A review of 19 projects, for a cumulative amount of 42.9 million euros (out of a total number of 164 projects, costing 255.3 million euros), that were implemented during the period 2011-2014, plus the ECHO Flight service contract¹⁵ for aerial transport (see list in Annex IV). The selection criteria included materiality, geographical and sectoral coverage, period of implementation, nature of aid and type of partners.

(d)Visits to the DRC from 16 to 25 September 2015 and to Tanzania, Rwanda and Uganda from 30 September to 8 October 2015 which included interviews with staff in the field, EU delegation staff, partners’ representatives and beneficiaries as well as on-the-spot visits to 10 projects.

14In the 2015 programming, the Commission decided to take Uganda out of the AGL HIP and add it in the Horn of Africa HIP. This is because an allocation for Uganda was approved under the HIP 2015 for the Horn of Africa region in order to respond to the influx of South Sudanese refugees and, according to a Commission internal rule, a country cannot be covered under two different HIPs.

15http://ec.europa.eu/echo/what/humanitarian-aid/humanitarian-air-services_en

Observations

Funding allocated to well established main priorities but insufficient clarity at further prioritisation stage

13

We examined whether the Commission allocated humanitarian aid to well established priorities by looking at how the humanitarian needs for the region were identified, what response the Commission envisaged and whether its support went to the most relevant projects.

The Commission has properly identified needs for the AGL region

The needs assessment is evidence based

14

The Commission performs annual needs assessments for all countries/regions to which it is already providing a financial contribution. It carries out ad hoc needs assessments whenever an unexpected crisis occurs, whether natural or man-made. In cases of deterioration of existing and already covered crises, the Commission updates its initial needs assessment. This is the main exercise in preparation for its annual programming, the Humanitarian Implementation Plan (HIP).

15

For the AGL region, the needs assessment is based on the accumulated knowledge and experience of the operational team in Brussels and the team in the DRC’s field office. The other main sources of information are (i) a range of internationally available indicators to determine a risk index value per country¹⁶ and (ii) the stakeholders in the field, namely the Office for the Coordination of Humanitarian Affairs (OCHA) for the DRC and the Commission’s partners, humanitarian donors.

16

The needs assessment for the AGL region gives a good overview of the situation in the DRC, both in conflict and non-conflict zones, and in neighbouring countries. The affected populations identified are:

(a)internally displaced people (IDPs) in the DRC;

(b)refugees, mainly Central African and Rwandan in the DRC and Congolese and Burundian in neighbouring countries;

(c)returned people (IDPs or refugees);

(d)host populations who need help to cope with the influx of refugees and IDPs;

(e)other local populations weakened by the conflicts or that are very vulnerable to malnutrition or epidemics in non-conflict zones.

17

The needs identified for these categories covered a wide range: protection, food security, nutrition, health care, water and sanitation, non-food items (NFI) such as pots and pans, clothing, soap, etc. and shelter. Education was not included as it was not deemed to have sufficient priority.

The Commission’s response is appropriate

Main priorities were well established

18

In the AGL region, the Commission’s overall objective is ‘to address urgent needs arising from population movements in conflict zone and life-threatening situations in non-conflict areas using the most appropriate response mechanisms’¹⁷. There are five ‘strategic objectives’ which lead to six envisaged actions/priorities (see Box 2). They are all in line with the Union’s principal objectives for humanitarian aid (see Box 1 in paragraph 4) and they allow the needs identified to be addressed. All the interventions have to target the most vulnerable populations.

Box 2

Main priorities:

(a)reducing protection risks and addressing protection needs,

(b)providing minimum basic services, health, food and NFI as fast as possible in emergency situations,

(c)providing support to the management of refugee camps in the region,

(d)providing water, hygiene and sanitation activities in areas at risk, outside conflict zones,

(e)giving priority to multi-sector approaches, and

(f)supporting coordination, security and logistics.

19

The main constraints faced by the Commission, and donors in general, are in the DRC. They are related to the challenging logistics in such a large country, the poor state of infrastructure and the lack of government’s capacity and willingness to contribute. The lack of partners in some parts of the country may also limit the capacity to make interventions. Finally, the security constraints, due to the constant shifting of military operations and subsequent movements of armed groups, curtail the activities of the donors, especially in the most remote areas.

20

The Commission’s response is consistent with the analysis of the situation and needs assessment. Both are consistent with the response described in the DRC’s Annual Humanitarian Action Plan (HAP) prepared by a team of humanitarian organisations representatives.

Flexibility in programming and in funding is ensured

21

In the HIP, the Commission does not impose areas/sectors for intervention which may be obsolete by the time of the selection. The Commission’s funding is driven by the most acute needs of the most vulnerable populations on the basis of the partners experience in the field, corroborated by the information shared by the humanitarian coordinator and the knowledge of the staff. Further prioritisation, mainly geographical, is done at the selection stage (see paragraph 25).

22

The Commission carries out a mid-term review of the HIPs on the basis of the subsequent year’s needs assessment. Moreover, the HIP is revised any time the evolution of the situation triggers a modification of the allocated amount. When an increase of the initial allocation is approved, the additional funding can be obtained from the operational reserve, an amount of approximately 20 % of the annual budget set aside for unexpected emergencies. It may also be obtained from the EU EAR or from the EDF budget.

23

For the AGL region, this flexibility has been used several times during the period under review to address the consequences of unexpected events or deteriorating situation (see Graph 2). In 2015 alone, due mainly to the Burundian refugee crisis¹⁸, the HIP for the AGL region was modified three times.

24

In addition, the AGL region operational team set aside a small share of the HIP’s allocation (approximately 1.5 million euros in 2015) for sudden increases in needs in the course of the year. This was used as a top-up for ongoing projects dealing with refugee camps in Rwanda and Tanzania as soon as it became known that high numbers of Burundians were fleeing the country at the end of April 2015. This allowed a prompt reaction while waiting for the approval of the first increase of the HIP which took place at the end of May.

Graph 2

Budget of the AGL region for the period 2011-2015

Source: European Court of Auditors.

Picture 2

Mahama refugee camp in Rwanda, newly built area hosting Burundian refugees

Source: European Court of Auditors.

Insufficient transparency at the project selection stage

Geographical priorities in areas of conflict are not documented

25

In the HIP, the geographical area of intervention corresponding to the conflict zones is Eastern Congo, which includes North Kivu, South Kivu and the different regions of the former province Katanga. In a volatile environment such as that in the DRC, more precise areas, where the most acute needs and most vulnerable populations are to be found, cannot be determined in advance.

26

According to the Commission, just before the assessment of the funding requests, the operational team defines top priority areas for allocating its support on the basis of information gathered on movements of the armed groups, including the FARDC, movements of population and the presence of partners. However, as this was not documented it was not possible to ascertain whether these geographical priorities were soundly based and whether the selected projects took place in top priority areas.

The selection process is not well documented

27

Over the period under review, 2011-2015, the Commission received on average 71 funding requests per year, following the first publication of the HIP, and selected around half of them. Depending on the evolution of the situation and the advent of new/increased needs in the course of the year, the Commission finally supported an average of 40 projects. The repartition of the HIP allocation is shown in Graph 1.

28

Partners receive comprehensive guidance regarding their funding requests which are submitted in an electronic exchange system in a predetermined format. All of these are assessed by the operational teams in Brussels and in the field and are discussed among these teams¹⁹. They present the final outcome of the selection in an internal document for decision. For the selected funding requests, the appraisal part of a document used for managing the project is then completed. This document provides information for each significant stage of the project cycle: funding request, interim report, field visits, modification requests and final report.

29

However, this appraisal part is not structured in such a way to demonstrate clearly that the criteria and general principles, detailed in the annex of the HIP, were assessed for each proposal. Some key aspects such as the partner’s implementation capacity, the partner’s knowledge of the country/region, protection and resilience aspects are not mentioned at all. For the projects examined, which were all in line with the main priorities and objectives set in the HIP, some general principles were not systematically assessed²⁰ or some of the assessments were weak²¹. From the information available it was not possible to determine the comparative merits of the funding requests submitted and therefore to conclude that the most relevant projects were selected.

Cost efficiency is not analysed

30

The budgets provided with the funding requests for the projects examined were not detailed and were not analysed prior to selection. Thus no assessments of these were made to determine if the proposed costs were reasonable. In the case of partners, usually UN agencies sub-contracting activities to implementing bodies, there was no information on the level of funding that went to these bodies. In general, no data was available on the level of aid spent on the beneficiaries.

31

In a context of ever-increasing humanitarian needs and ever tighter funding possibilities, efficiency aspects are of even greater importance. Moreover, in the absence of adequate checks to ascertain that the budget is reasonable at the selection stage, subsequent analyses on the execution of this budget have limited use.

Overall, the Commission’s monitoring is appropriate although the information obtained could be better used

32

We examined whether the Commission obtained adequate information from project reporting to monitor progress and took appropriate and timely measures when needed.

In most cases, the Commission obtains adequate information on project implementation

The monitoring framework in place is appropriate

33

This framework is based on:

(a)an interim report, due 3 months before the end of actions whose duration exceeds 10 months, and a final report, to be submitted within 3 months following the end of the project and triggering the final payment (see Annex V);

(b)a minimum of one field visit per project by Commission staff, provided that security or logistical constraints allow for that²².

34

In addition, the Commission carries out periodic, usually annual, assessments of the partners, focused on their financial soundness. The Commission also supervises audits, sub-contracted to external audit firms, at partners’ headquarters and in the field. Considering the nature of the actions and their duration, the monitoring framework in place is satisfactory.

The timeliness and quality of some reporting was unsatisfactory

35

Interim and final reports are submitted through an electronic exchange system in a predetermined format. They should include updated operational information, on the values reached per indicator and financial information, namely the budget consumption, to allow the Commission to conclude on the progress of an action as a whole. The analysis of these reports and the reporting on the field visits is entered in its supervision document.

36

Many interim and final reports were considerably delayed and no explanations for these delays were demanded by the Commission. In particular, a high proportion of interim and final reports for projects implemented by UN agencies and IOs was not submitted on time (see Table 1). The late submission of interim reports curtails the Commission’s ability to address any problems that may be identified.

37

While, overall, the quality of the interim reports was satisfactory, we considered that only three out of the 18 final reports²³ were satisfactory. In the 15 other cases, the initial information reported was not sufficient to explain the level of performance achieved, the impossibility of using some indicators or why some activities had not been carried out. In some reports supporting documentation for the provided data was missing and financial information was not detailed enough. In all cases but one²⁴, the Commission requested supplementary explanation from the partners. They provided additional information which in all cases but two²⁵, was deemed satisfactory.

Table 1

Timeliness of submitted reports

| UN Agencies | International Organisations | NGOs | Total
Interim reports
Total number of Interim Reports submitted | 5 | 3 | 7 | 15
Number of Interim Reports delayed | 2 | 2 | 2 | 6
Percentage of late Interim Reports | 40 % | 67 % | 29 % | 40 %
Average delay (days) | 32 | 17 | 9 | 19
Final reports
Total number of Final Reports submitted | 8 | 3 | 8 | 19
Number of Final Reports delayed | 8 | 2 | 3 | 13
Percentage of late Final Reports | 100 % | 67 % | 38 % | 68 %
Average delay (days) | 34 | 102 | 17 | 41

38

A key feature of the Commission’s intervention in the AGL region, in comparison to most other humanitarian donors, is its field presence (see paragraphs 9 and 10). This allows for collaboration and exchange of information with partners and enables the Commission to have solid knowledge of the projects. This on-the-spot presence was much appreciated by the partners met during the audit who valued the support and expertise provided by the Commission staff.

39

However, one quarter²⁶ of the field visit reports were not comprehensive as they commented on certain aspects only and other matters such as financial implementation were not reported. In a few cases, the potential effect of detected issues on the results or the budget implementation was not analysed (see examples in Box 3) and no potential mitigating measures were proposed.

Box 3

Examples of lack of analysis of the implications of detected issues in field visit reports

In two cases, a project to improve the food security situation of conflict-affected populations in Katanga (n°11) and another to provide free healthcare for vulnerable populations in South Kivu (n°19), the projects’ durations were extended because there were delays in the implementation resulting in an underutilisation of the budget. The extensions were granted shortly before the end of the projects.

The reports of the field visits that took place shortly before the extensions were granted did not analyse the effect on the budget and did not outline the necessity for an extension.

Furthermore, the last field visit report for the food security project in Katanga, failed to highlight the impact on the project’s targets (number of beneficiaries, indicators of food distribution and consumption reached, etc.) as a result of funding not received from other donors (final budget less than 50 % of the initial budget).

40

The Commission could not explain how the methodology used was applied to select the partners/projects audited in any specific year in the 2011-2015 period. The lack of a clear methodology for programming of audits at both partners’ headquarters and field level may lead to inappropriate audit strategy and coverage and does not facilitate synergies with the monitoring framework in place.

Follow-up is insufficient

There is no consolidated reporting giving an overview of the HIP’s implementation

41

The Commission only assesses results at project level, but there is no overview for a given country or HIP. Consequently, no aggregated analyses at HIP level are available and no benchmarking between HIPs is possible. Similarly, the main lessons learned, best practices and the Commission’s added-value identified in the course of the implementation are not reported.

42

Every year the Commission selects and evaluates a number of thematic and geographical areas of intervention in line with its planned multi-annual coverage. The last evaluations dealing with the AGL region were country evaluations and took place in 2009 for Burundi, in 2010 for the DRC and in 2011 for Uganda.

The follow-up of issues identified at project level is not systematic and lacks documentation

43

The individual management document has a specific box for ‘issues for follow-up’. Some issues raised during the field visits and in partners’ reports were not mentioned in the box even when they obviously necessitated remedial action. In addition, when issues were raised for follow-up, there was nothing to indicate that these had been raised with the project partner. Finally, there was no indication that the problems in question had been addressed.

44

‘Issues for follow-up’ were specifically identified for 14 projects under review in our audit but only two partners reported directly on the actions taken. While in some cases there were indications that measures had been taken by the partners, there is no assurance that this is done systematically.

Most of the projects examined delivered satisfactory results

45

We examined whether the intended project results were delivered as planned and whether the Commission was responsive to changes in the field.

Overall outcomes achieved are positive but in some cases, the Commission’s assessment is not clearly justified

46

All the projects we examined were in line with the Commission’s objectives and with the envisaged actions for the region. Out of the 20 projects examined, 19²⁷ were found to have delivered satisfactory results despite partial achievements of targets (see example of successful project in Box 4). The assessment of project results is based on the comparison between set and achieved targets taking into account the particular difficulties arising in this area of operations.

Box 4

Example of a successful project: Rapid response to movement of populations (RRMP, n°15):

This project is one of the Commission’s main vehicles for emergency response related to movements of populations in the DRC. It is a recurring project and the Commission’s funding over the period 2011-2015 amounted to 31.5 million euros.

It provides multi-sectoral assistance, shelter, NFI (pots and pans, clothes, soap, etc.), water, sanitation, and health care in areas where no other humanitarian organisations are present. Interventions consist of the distribution of NFI and shelters, provision of water, sanitation and health care to the most vulnerable populations who have fled from armed groups or returnees that are just back in their villages but have nothing left. Interventions are usually limited to 3 months.

From May to December 2014, the project allowed assistance to be provided to approximately 1.3 million beneficiaries, mainly in North and South Kivu, Maniema and Province Orientale.

On average, 35 % of the interventions took place within 30 days of the movement of population alert compared to a target of 40 %.

Despite partial achievement of some initial targets, this project was judged successful considering the context in which it is implemented and the number of beneficiaries reached.

Picture 3

Rapid Response to Movements of Population: distribution of NFI in Lulingu, Shabunda territory, South Kivu, people retrieving their goods

Source: European Court of Auditors.

47

In some of the cases where the Commission’s assessment was positive despite partial achievement of the targets, it did not provide enough explanation to substantiate its position. In four cases we found that the assessment of the overall project achievement and of the partner’s performance was inadequate and did not provide a clear conclusion on the project. Consequently, a clear logical link between the Commission’s overall conclusion on the project and the results achieved could not be established.

48

For the projects examined, one was found to have unsatisfactory results (see Box 5). Contractually, the Commission can reduce its contribution in the cases of poor, partial or late implementation of a project, without acceptable justifications provided by the partner. This option was used for one case with unsatisfactory results but is seldom used as it is cumbersome to implement and could result in the loss of budgeted funds. Thus, in case of unsatisfactory results and/or partner’s performance, the Commission’s preferred option was to reduce the subsequent year’s contribution²⁸ or to stop the collaboration with the partners²⁹.

Box 5

Spontaneous Site Management and Coordination in the DRC (n°18)

This project was initiated in 2013 and funded by the Commission with an amount of 2 million euros. The funding for this partner reached 3 million euros by the end of 2015.

The project’s objectives were:

(1)to gather and disseminate information on the managed sites;

(2)to manage and coordinate the provision of assistance such as water, sanitation, shelter and non-food items;

(3)to digitally register the IDPs in the managed sites.

The target values for (1) and (2) were eventually reached but due to a delay in procuring equipment the supply of non-food items was delayed by 14 months. For (3) the digital registration was delayed by 10 months and reached only 25 % of the targeted number. Only 24 % of the beneficiaries expected to be covered by the whole project were reached.

ECHO considered that the performance of the partner was not satisfactory: its project management skills were limited, the administrative procedures were cumbersome and its monitoring of the implementing partner was insufficient. All this negatively impacted the outcome of the action.

Despite the unsatisfactory implementation, the Commission reduced its contribution by 57 000 euros only. Furthermore, the partner was contracted again the subsequent year but for a lower amount of contribution.

The Commission also identified ineligible expenditure but given that the total amount of eligible expenditure was still higher than the Commission’s maximum contribution, this did not impact the amount of the contribution paid.

49

For the only contract in the selection awarded following a tendering procedure, ECHO Flight (n°16), more than 10 500 people and 250 tons of merchandise in the DRC³⁰ were transported from May 2014 to March 2015 (11 months). Through this contract, the Commission ensured its partners, and their cargo, secure and rapid access to remote locations which would otherwise be virtually impossible to access. It thus provided humanitarian assistance to vulnerable population and fulfilled one of the main priorities in the HIP.

The Commission was responsive to changes but could better justify time extensions granted

50

About half³¹ of the projects in the audit sample were implemented over a longer period than initially planned, from 2 to 6 months, or with more budget (see details in Annex VI). Five out of seven time extensions, without budget increase, were granted in cases of budget under-consumption, related to delays in implementation mainly justified by external factors. Most of the increases in budget, five out of seven, were related to additional needs resulting from the deterioration of the situation or the lack of stabilisation.

51

In one case, the main reason for the extension was to give the partner additional time to ‘organise the transition from the Commission funding to another mechanism’. The Commission itself acknowledged in the assessment of the modification request submitted by the partner that it had ‘not prioritised this project for 2014’³².

52

In two cases, the extensions were granted when the implementation delays were mainly the partners’ responsibility. In those cases, the Commission decided not to recover part of the funding and not to reallocate this to other projects (see paragraph 48). Instead it chose to give the partners an opportunity to implement as much of the project as possible thus ensuring that beneficiaries would receive the aid. Nevertheless, the extension of the duration was not primarily driven by the prioritised needs and vulnerabilities.

There is limited evidence of what is being done to link Relief, Rehabilitation and Development

53

Linking Relief Rehabilitation and Development (LRRD) and better coordination between development and humanitarian activities are policy priorities in the Commission’s strategy. However, there was no analysis of potential programmes which could be combined and what could be put in place in the region. For instance, there is no mention of the Commission’s possible participation in the elaboration of the Health LRRD strategy, one of the specific objectives in the health focal sector under the National Indicative Programme (NIP) under the 11th European Development Fund 2014-2020 for the DRC³³.

54

For the period under review, there was only one example of a humanitarian project being integrated in the health programme developed under the NIP 2014-2020 for the DRC³⁴. In Uganda, refugees are given a plot of land and some rights to participate in the local economy³⁵. Humanitarian aid support services, for instance health care, were also used by the local population which is best practice to lift the burden on the host communities and avoid tensions with refugees. However, there were no examples of synergies with development programmes. This may result in humanitarian aid substituting other sustainable solutions, such as return, resettlement to another country or local integration.

55

OCHA, the humanitarian coordinator for the DRC, recognised that more effort should be put into the coordination between humanitarian and development actors. This was also identified as a priority area for the DRC’s forum of humanitarian donors, called the Good Humanitarian Donorship group³⁶ for 2015. A recent report from the World Bank³⁷ also recommended that ‘development agencies should become more involved in addressing displacements in the Great Lakes Region’.

16See webpage: http://www.inform-index.org/Home

17HIP AGL 2015 version 4, point 4) envisaged ECHO response, p. 10.

182 million euros were also added to the initial 2015 allocation for the AGL region because of the inflow of ± 80 000 of Central Africans to the DRC.

19The bulk of the funding requests are submitted around the indicative date mentioned in the first version of the HIP, usually towards year end or at the beginning of the subsequent year.

20(1) Adaptation to the specific needs related to gender and age. (2) Integration of resilience activities by identifying the possibilities to reduce potential risks for vulnerable people and to reinforce their livelihood, this also includes the recommendation from the Commission to its partners to explore from the beginning possible synergies and complementarities with development and national actors. (3) Integration of protection activities which objective is to reduce physical and psychological insecurity for persons and groups under threat.

21Weak or incomplete project appraisal was also mentioned by the Internal Audit Service of the Commission in its audit report on Contribution Agreements with UN bodies and other International Organisations of 19.6.2014.

22Any exception should be justified as it was the case for two projects in our sample.

23One final report was not received at the end of the audit.

24In one case, DG ECHO did not respect the deadlines for reviewing final reports and was not able to send a request for information.

25Food assistance for refugees in the Northwest of Tanzania and Spontaneous Site Management and Coordination in the DRC.

26For the 20 projects examined, a total of 33 field visits were performed. For nine of them, the monitoring report contained limited comments.

27One was not satisfactory.

28This was the case for at least two partners in 2015.

29For instance, in the selection process for 2015, three requests for funding were rejected by ECHO partly because of implementation problems identified during ECHO’s monitoring of previously funded projects.

30The contract provides with air transport services for cargo and humanitarian actors also in Kenya and other locations when needed (Mali, Chad, etc.).

3110 out of 20 projects. Increases related to the payment appropriations shortage in 2014 are not counted. All the extensions were formalised in contract amendments.

32Project n°6. Extract of ECHO’s technical assistant in the field assessment of the modification request from the partner.

33See pp. 10-12 of the NIP 2014-2020.

34The HIP 2015 indicated that the Commission was continuing the funding for the project in 2014 with humanitarian aid, until the agreement for funding development aid was finalised.

35Uganda is also hosting South Sudanese and Central African refugees that were not in our audit scope, in other parts of the country. Thus, our comments here are limited to Congolese refugees’ settlements.

36See more details in http://www.ghdinitiative.org/.

37http://documents.worldbank.org/curated/en/2015/01/24356083/forced-displacement-great-lakes-region, see p. 11.

Conclusions and recommendations

56

The humanitarian aid to populations affected by conflict in the Great Lakes area was, generally, managed effectively by the Commission. The needs assessment was thorough and the approach adopted had sufficient built-in flexibility to cope with the rapidly changing circumstances in the conflict-affected areas. Extra funding was available for emergency situations such as the aftermath of the crisis in Burundi. The projects examined were mainly successful in addressing urgent needs.

57

A number of weaknesses were identified, some of which related to insufficient transparency at key stages in the life cycle of projects. While the project management information system maintained by the Commission provides useful data on the project’s life cycle, it does not meet information requirements in some specific areas.

58

The main priorities for the region were determined on the basis of needs assessments and the funding was allocated according to these priorities. However, it was not possible to determine if the proposals selected were in the priority locations as this further prioritisation was not documented. Neither was there sufficient evidence to show that all the relevant criteria and general principles were applied for the approval of project proposals, as this process was not documented in a transparent manner. The system did not give sufficient information to assess the comparative merits of the projects and determine if the most appropriate projects were selected.

Recommendation 1
The Commission should be more transparent in the selection procedure

The key stages of the selection process should be clearly documented in order to show that the most appropriate proposals are selected and to ensure that the selection process is transparent. This should be implemented by the next selection phase.

59

In addition, the budgets accompanying the proposals were not examined to assess the reasonableness of the costs therein. In fact, in some cases the budgets presented were inadequate for any assessment to be undertaken. This has not only consequences at the project approval stage but it also means that cost analysis at further stages for control purposes may not be soundly based.

Recommendation 2
Costs of proposals should be better analysed prior to acceptance

The Commission should pay more attention to the proposed project costs and these should, in all cases, be assessed for their reasonableness. In this regard, the Commission should insist on the submission by its partners of budgets, which provide the necessary information for analysis. A short checklist could be introduced to provide evidence of compliance with these control features. This should be implemented by the next selection phase.

60

Considering the nature of the actions, the monitoring framework in place is satisfactory as it balances ECHO’s need for information with the requirement to minimise the administrative burden. However, information supplied by partners in their interim and final reports was frequently late and hindered the Commission’s ability to address, quickly, any issues raised and to learn lessons for future programming. While there were indications that follow-up had been undertaken in some cases, this was not ensured as the issues and subsequent actions taken were not systematically recorded. An important feature of monitoring is the presence of field officers on the spot, which is of mutual benefit to the partners and the Commission. However, reporting from field officers did not, in some cases, identify key issues. Overall, the monitoring is appropriate but more thorough follow-up is required.

Recommendation 3
The Commission should make clear the extent to which problems raised for follow-up are resolved

The management document for each project should be revised by the end of this year to include the necessary features to clearly identify issues arising for further action and the follow-up undertaken.

Recommendation 4
Better reporting from partners and field staff should enable prompt action to be taken

Partners should be continuously reminded of their responsibilities to report comprehensively and in good time. A checklist for Commission staff should be introduced for the field visits so that the key issues are covered. This should be implemented by the end of this year.

61

The overall implementation of the Humanitarian Implementation Plan is not assessed. As a result the lessons that could be learned from its strengths and weaknesses are not identified for future use. In addition, an assessment of this nature would provide useful summary information for management purposes. It was also noted that no evaluation in the Great Lakes area has taken place in recent years.

Recommendation 5
The Commission should introduce an overall reporting system on the implementation of the HIP

The Commission should introduce a system of reporting at HIP level outlining the main outputs and outcomes, identifying the main lessons learned and best practices to be applied in subsequent years’ HIPs. It should also deal with strategic issues such as what approach to adopt in a protracted crisis.

62

Overall, the results achieved for the sample of projects examined were satisfactory. One partner, however, managed to spend most of its budget despite achieving a small percentage of some planned results. In a few cases the justification for time extensions and additional budgets was not clear. As regards the Commission’s own assessment of results it was unclear, in some cases, from the information available, how they arrived at their conclusions.

Recommendation 6
The Commission should establish a clear link between results achieved by a project and the assessment used to make the payment

The Commission should better design, structure and document the assessment of an action that is only partially achieved and establish a clear link between the results achieved and the overall conclusion on a project, before authorising final payment. This should be implemented at the earliest possible stage.

Recommendation 7
Time extensions and additional funding for projects should be clearly justified

The Commission should provide clear justifications for additional funding and time extensions granted to partners and should respond firmly to all instances of under-performance. This should be implemented for all future requests for extensions.

63

While Linking Relief Rehabilitation and Development is an expressed policy of the Commission there is not much evidence of how this is implemented. In practice it is more likely that Humanitarian Aid will be used in cases where other sustainable solutions, such as return, resettlement to another country or local integration would seem more appropriate.

Recommendation 8
The Commission should prioritise the linking of Relief Rehabilitation and Development

All opportunities should be exploited to link efforts in the relief, rehabilitation and development areas. This will involve placing this consideration high on the agenda at key stages in the planning process.

This report was adopted by Chamber III, headed by Mr Karel PINXTEN, Member of the Court of Auditors, in Luxembourg at its meeting of 10 May 2016.

For the Court of Auditors

Vítor Manuel da SILVA CALDEIRA
President

Annexes

Annex I

Map of the African Great Lakes Region

Annex II

DRC Refugees at the beginning of 2016

Source: http://data.unhcr.org/drc/regional.php

Annex III

Map Burundian refugees at 26 January 2016

©UNHCR, UNCS, Author: UNHCR Regional Service Centre Nairobi. Source: http://data.unhcr.org/burundi/regional.php (see section Maps).

Annex IV

List of projects examined

(a)Continued under the regional project.

(b)Project continued but with a different partner as from 2015, the implementing partner remains the same.

 Final payment not yet made, amount still provisory.

Annex V

Interim and final reports examined

Annex VI

Amendments to projects reviewed

 Increase of budget related to the payment appropriation shortage in 2014

 Extension of duration in cases where funds were still available towards the end of a project

 Increase in budget related to new/additional needs

 Projects with increase in funding and/or extension in duration

Reply of the Commission

Executive summary

V

More formal documentation on the compliance with mandatory criteria could be useful. However the fine-tuning of geographical priorities is done on a constant basis through the presence of the Commission's field staff in humanitarian coordination fora, and written weekly updates on the humanitarian situation. Finally, the Commission analyses the reasonability and completeness of the overall budget structure, and its consistency with the proposed actions.

VI

Due to the whole framework of communications channels and monitoring tools set by the Commission, no systematic link can be established between late submission of a report and late identification of problems.

VII

With regards to the justification for time extensions and additional budgets, the Commission points out that, for each project amendment, the FichOp¹ contains a justification for extending the project duration in line with applicable procedures.

VIII

While recognising that it remains a priority, the constraints associated to the implementation of LRRD in DRC are significant and need to be acknowledged. The Directorate-General for International Cooperation and Development (DEVCO) and the Directorate-General for Humanitarian Aid and Civil Protection (ECHO) are closely cooperating for ensuring LRRD and to share information concerning the humanitarian situation in the different areas, resulting for instance into a LRRD health programme in DRC for the 11th EDF.

Observations

17

As of 2016, education in emergencies has become a priority for humanitarian aid interventions worldwide with an allocation of 4 % of the overall budget.

Insufficient transparency at the project selection stage

The Commission considers that the issue is insufficient formal documentation rather than insufficient transparency.

26

The fine-tuning of geographical priorities is done on a constant basis through the presence of our field experts in all humanitarian coordination fora. In addition there are weekly written updates of the humanitarian situation, which feed information with the latest situation updates into the programming exercise.

Considering the Commission's presence on the field, close coordination with other actors, and clear entry criteria for the Commission's interventions (population displaced as a result of armed conflict resulting in acute humanitarian needs), there is no doubt that projects selected fall into top priority areas. However, all projects submitted under a priority area are not systematically selected if any other mandatory criteria are not fulfilled and/or because of lack of funding.

In addition the Commission is increasingly selecting partners for emergency preparedness and response in widely-defined geographical areas in order to account for all the ‘hotspot’ areas that develop in the East of RDC during the year.

29

The FichOp guidelines, approved by Management in March 2016, provide guidance on proposal analysis in order to substantiate the conclusions to be reported.

With regards to general principles which were not systematically assessed, the Commission underlines that gender and age/resilience markers were only introduced recently, and are mandatory respectively since July 2014 and January 2015. Yet the sample taken by the Court (all except for one project launched before 1 July 2014) corresponds to a period where these markers were not yet established.

As far as protection is concerned, in only very few cases the component was not explicitly assessed in the request appraisal.

30

Concerning the level of detail of the budgets provided with the funding requests, the Commission considers that the level of detail of the budget provided by partners is sufficient to assess reasonability of the proposed costs. The level of detail is determined in the General Conditions and in the FPA guidelines, as well as in the FAFA.

The Commission analyses, inter alia, the overall budget structure and consistency with the action proposed. The Commission services analyse the reasonability and completeness of the budget (and its breakdown) and its consistency with the actions proposed, using historical benchmarks, when available, or local market information.

31

Please see the Commission's reply to paragraph 30 above.

33 (b)

The Commission would like to add that almost half of the audited projects had been monitored twice.

36

The late submission of interim reports does not systematically curtail the Commission's ability to address any problems identified. Indeed, and as results of other communication channels and monitoring tools, no systematic link can be established between late submission of a report and addressing problems that can be identified even before the reception of the interim reports.

The Commission has an overall monitoring framework which includes field visits. These regular field visits performed by humanitarian experts constitute the most important tool to assess whether expected activities/results are effectively taking place according to plans (reality check). These field visits are complemented by continued dialogue at field level with partners. Through this presence in the field, any problem is rapidly identified and followed up with the partner.

39

Financial data are not always available at field level during field visits carried out by Commission staff. This explains why ‘financial implementation’ is most of the time not reported upon in the FichOp. The Commission will reflect on how to address this issue.

Box 3 - Examples of lack of analysis of the implications of detected issues in field visit reports

In the case of the multi-donor UN food security project in Katanga, budget monitoring of the action is done at national level, and not at provincial level. The UN agency launches a funding appeal along the entire year. Contributions from other donors are ongoing and evolving regularly along the year so it is only at the end of the year that the partner can share the overall budget of the action when all contributions are recorded. Therefore, financial data were not available during the field visit carried out by Commission staff and therefore it was not possible to reach any conclusion on that aspect.

Furthermore, in a multi-donor action, the provisions of the FAFA are applicable. In such cases, the total eligible costs of the action referred to in the Special Conditions is considered as an estimation that can evolve during the implementation of the action, i.e., if the contribution expected from other donors does not materialise. Modifications in the overall action budget will not themselves trigger any change in the Commission's contribution. For this reason, the partner did not formally inform the Commission of the changes in the overall action budget and was not bound to submit a modification request. For multi-donor actions with IOs or UN bodies, the partner may update the figures unilaterally at the next reporting stage to reflect the budget change.

40

The current audit strategy expired at the end of 2015, and a new audit strategy for the period 2016-20 (including a new sampling methodology) is in the course of being approved by ECHO senior management. The new methodology seeks indeed to have more synergies with the monitoring framework, in particular by taking into account the risk analysis on partners and actions made by the operational units.

42

An evaluation was foreseen for DRC in 2016 and it became no longer a priority as a result of the ongoing performance audit. It is likely to be added to the 2017 evaluation programme.

44

This is clearly an issue that would need some adaptations to the current information system (APPEL), and the Commission will explore possibilities to address this weakness.

47

The Fiche Op guidelines approved in March 2016 by the Commission should indeed contribute to improve consistency on the level of information contained in the assessment.

48

The procedure to reduce the Commission's contribution as a result of poor/partial/late implementation has been seldom used.

It is challenging to assess with precision and accuracy whether unsatisfactory results are the consequence of poor performance or are contextually related (change of context, lack of access, security and logistical constraints).

The provisions of the new 2014 FPA sets up that the Commission may reduce the grant if the action is not implemented or is implemented poorly, partially or late. The Commission has reinforced and clarified the internal procedures to ensure that any reduction is legally sound and proportionate to the gravity and scope of the failing. When the results have not been achieved, the certified correct provided by the AOSD includes an annex justifying the reduction of the contribution for underperformance or a justification based on ‘force majeure’ arguments.

However, there is very little risk that the use of the underperformance procedure could result in the loss of budgeted funds as possible disengaged amounts can be made available for other projects within the implementation time of the related HIP (24 months). The capacity of reutilisation of possible disengaged funds is testified by the implementation rate of ECHO, stable at around 98 % over the years.

Box 5 - Spontaneous Site Management and Coordination in the DRC (n°18)

The amount of 57.300 euros was calculated based on the total costs of the result 3 (572.998 euros), result partially achieved due to delay in the implementation. The Commission has applied an under-performance rate of 10 % in addition to the ineligible costs deducted.

The partner was indeed contracted the subsequent year, as it is the mandated partner for Camp Coordination and Camp Management (CCCM) at national level and therefore is key partner in dealing with population displacement issues in conflict areas. The Commission decided however to reduce its contribution but to maintain some support for strategic reasons.

51

The fact that the caseload of refugees had significantly decreased over the years (from 250,000 to less than 70,000 people) pushed the Commission to rationalise its support through the leading agency (decrease of caseload, hence decrease in the number of partners funded).

However, as Commission support had already been granted for several years to the partner for this action, a smooth exit strategy/hand over with the lead agency was desirable to limit the negative impact it could have on beneficiaries (ensuring continuity of basic health services). In this sense a modification extending the contract for 6 additional months, with additional funding of 450,000€, was granted on the 2013 HIP, using available funds.

52

The extension of the duration of the action mentioned was primarily driven by the prioritised needs and vulnerabilities. The drivers for accepting these extensions have always been related to beneficiaries' needs – in giving additional time to the partner, the Commission has clearly prioritized the fulfilment of immediate beneficiaries needs. Choosing recovery or reallocation to other projects would have taken too much time and left unfulfilled current needs. This was not seen as a realistic option.

53

The Commission's Humanitarian and Development DGs are closely cooperating in exploring all options possible for ensuring LRRD and usually share information concerning the humanitarian situation in the different areas of the DRC. It remains a priority at Commission level but constraints associated to the implementation of LRRD are significant in the context of DRC.

As far as DRC is concerned, the Commission's development works in the spirit of the Cotonou agreement, where DRC Government is in the driving seat and defines priorities. The only focal sector with a theoretical potential link with the Commission's humanitarian aid is health. The Government has a policy of focusing development and bilateral aid to neglected areas in non-conflict areas, because they appear abandoned by international actors when compared to the conflict affected areas in the East. It is a natural reaction from the perspective of development actors and national authorities to focus on these areas, because they offer stability and security and do not present risks regarding projects being abandoned due to violence. Investing in stable areas is therefore more likely to have some impact on poverty reduction. In addition, the conflict areas in the East (where the Commission's humanitarian aid is focused) are perceived - rightly so, as benefiting from the presence of the bulk of the humanitarian community (NGOs), whereas very few organizations are present in the rest of the country to work with structural problems and chronic poverty. The Commission cannot be expected to launch LRRD discussions in areas that present a medium term risk of projects being abandoned or severely affected due to an emergency. In the last 5 years, the only area in the East that has witnessed a relative stability has been the ex-LRA (Lord's Resistance Army) affected areas in Haut Uele and Bas Uele (north part of Province Orientale), which is exactly the place where a successful LRRD transition has been negotiated between Commission services. In the rest of the areas of Eastern DRC where the Commission's humanitarian aid is present, instability continues and we cannot show a single area on the map that has been without activity of armed groups, killings and/or displacement for more than a year at a time.

Opportunities are therefore limited by nature in such context but when conditions are met geographically (areas becoming stable), fit with Government priorities/focal sectors (health) and priority areas (Kasaï Oriental, Lomami, Kasaï Central, North Kivu, Ituri, Haut Uelé, Kongo Central), LRRD is strongly encouraged. This scenario has indeed occurred once during the timeframe of the audit (see above)

More recently, DEVCO and ECHO engagement in discussing the transfer of support to Panzi Hospital in South Kivu province has materialised in a DEVCO project of 3 million EUR (funded under the Global Public Goods and Challenges programme). This action will aim at aligning the centre to the standards of the general hospitals supported by the EDF national health programme in order to allow for a potential future inclusion in it.

Other LRRD initiatives are taking place in non-conflict areas (in the sector of food insecurity in Kasai provinces and in health and water sectors in cholera affected areas).

54

Taking into account the prevailing situation in Eastern DRC, particularly in security terms, it was not possible to implement more than one LRRD project so far (health). The Commission will nevertheless continue to seize any existing opportunity for LRRD (for example: initiative in South Kivu to support Panzi hospital or mission to North Kivu considered by the EU Delegation in DRC). A health specialist has been recruited by the Commission to continue exploring all possible LRRD avenues.

In regards to Uganda, the Commission points out that the Government of Uganda has designed a development plan in which refugees are included and through which Humanitarian and Development actors are brought together to look at long-term solutions for the refugees involving the host communities.

55

The fact that this issue is not being resolved and comes back every year as a priority suggests that there are a number of constraints/challenges that keeps it from happening.

Several generations of experienced development and humanitarian experts have tried hard to get around that issue, without much success. Even MONUSCO, with a dedicated Stabilisation Unit, have been making plans and running meetings for the last two years on ‘stabilizing’ areas liberated from the M23 rebellion, and do not have a single project to show for, not to mention that the ex-M23 areas are today part of the least safe places for aid workers (and even less appropriate for development actors that has a lower risk-taking threshold).

The underlying problems that stop progress on LRRD are the same that have been identified by the different services of the Commission; a context of conflict, insecurity and population displacement that is not conducive to development actions. LRRD can take place only when a minimum of conditions are met and in the conflict areas where ECHO has been working, these conditions do not exist.

Conclusions and recommendations

57

The Commission considers that the issue is insufficient formal documentation rather than insufficient transparency.

Recommendation 1

The Commission accepts the recommendation. It considers that the issue is insufficient formal documentation rather than insufficient transparency.

The Commission has already taken steps in this regard through the adoption of the FichOp Guidelines in March 2016. A continued training programme will also be designed to ensure that staff is familiar and able to follow these guidelines.

59

The level of detail of the budget provided by partners is determined in the General Conditions and in the FPA guidelines. This level of detail is considered as sufficient to assess reasonability of the proposed costs. Increasing the level of information would not have a real added value.

Recommendation 2

The Commission accepts this recommendation.

On the one hand, the Commission notes that the budget, as per its definition included in the General Conditions and in the Guidelines for FPA and FAFA partners, is sufficiently detailed so as to make an assessment of the reasonableness of the costs needed to achieve the results. The Commission services do already analyse the reasonability, completeness and consistency of the budget (and its breakdown) with the actions proposed, using historical benchmarks, when available, or local market information.

On the other hand, a checklist to document this analysis, or short guidelines on appraisal, may be needed.

60

The late submission of information by partners does not systematically hinder its ability to address, quickly, any issues raised and to learn lessons for future programming. Thanks to the communication and monitoring framework established by the Commission with its partners, no systematic link can be established between late submission of a report and any difficulty in the early identification of problems. Regular field visits by Commission staff constitute a tool to assess whether expected activities/results are effectively taking place according to plans (reality check). These field visits are complemented by continued dialogue at field level with partners.

Recommendation 3

The Commission accepts the recommendation and will explore ways to improve the internal reporting system in that respect.

Recommendation 4

The Commission accepts the recommendation that monitoring visits should result in a systematic assessment of key issues. The FichOp Guidelines that have been introduced in March 2016 contain a section on monitoring providing guidance to Commission staff performing monitoring visits. It is envisaged to organise training sessions in order to promote and ensure the systematic use of these Guidelines. However, the introduction of a checklist is considered to be redundant.

61

An evaluation was foreseen for DRC in 2016, but it became no longer a priority a result of the ongoing performance audit. It is likely to be added to the 2017 evaluation programme.

Recommendation 5

The Commission accepts the recommendation and will look at options that would serve the purpose of the recommendation, taking into account the efficiency of the overall reporting architecture.

Recommendation 6

The Commission accepts this recommendation and considers that it has already taken steps in this regard through the adoption of the FichOp Guidelines in March 2016. The Guidelines should indeed contribute to improve consistency on the level of information contained in the assessment and to establish the required link between the results achieved and the overall conclusion.

Recommendation 7

The Commission accepts that clear justification for additional funding and time extensions is needed. In fact, an adequate framework is already in place. All time extensions and additional funding for projects are approved on a basis of a justification provided by the partner. The justification's assessment, done by field and HQ staff, is ultimately recorded in the FichOp for approval by management.

Recommendation 8

The Commission accepts the recommendation on prioritising linking relief, rehabilitation and development, and will pursue its multiple efforts to put this into concrete actions.

While the Commission continues to keep this overall objective high in its agenda, the specificities of the DRC context make this objective extremely difficult to reach as constraints can hardly be overcome.

1The FichOp (‘fiche opérationnelle’) is a tool used by DG Humanitarian Aid and Civil Protection (ECHO) which documents all main aspects of the operational analysis and follow-up made by Field Experts, Desk Officers, Desk Assistants and Financial Officers on the humanitarian actions all along the action’s cycle and serves – at a later stage –for statistical purposes and audit trail. It is mentioned in paragraph 28 of this report.

QJ-AB-16-014-EN-E    ISSN 1977-5679

The auditors conclude that humanitarian aid to the populations affected by conflicts in the African Great Lakes area was generally managed effectively by the Commission.
The funding was allocated to well-established main priorities, but there was insufficient clarity at a later stage when further specifying priorities and selecting projects. It was not possible to determine whether the most suitable projects had been selected.
Overall, the Commission’s monitoring was appropriate, although it could have made better use of the information it obtained. Finally, taking into account the particular challenges faced in the region, most of the projects examined delivered satisfactory results.