ANALYSIS OF INTERNATIONAL

EXPERIENCE AND BEST

PRACTICES IN TRANSPARENT AND
ACCOUNTABLE RECOVERY EFFORTS
MAY 2022
1
The Better Regulation Delivery Office (BRDO) was established in November 2015 to help create effective
regulation and improve economic freedoms in Ukraine (with a priority for small/ medium-sized businesses).
The document was prepared by experts from the Better Regulation Delivery Office

Project Manager:      Ihor Samokhodskyi

Experts from BRDO:
Nadiia Kostryba
Dmytro Lebedyev
Kateryna Kykot
Yuliia Moskalenko
Konstantyn Chyzhyk

This report is made possible by the support of the American People through the United States Agency for Interna-
tional Development (USAID).The contents of this report are the sole responsibility of the grantee organization and
do not necessarily reflect the views of USAID or the United States Government.

2
TABLE OF CONTENTS

Military-political context 5
Typical forms of assistance 6
Corruption risks 15
Main stages of recovery and the corresponding risks 23
Corruption risk management 33

3
Abbreviation

ADB Asian Development Bank

ARC Autonomous Republic of Crimea
DPR “Donetsk People›s Republic”
DRR-PFM The Disaster Resilient and Responsive Public Financial Management
EU European Union
GPPB Government Procurement Policy Board
IFO International financial organizations
ISAF International Security Assistance Force
LPR “Luhansk People›s Republic”
MDTF Multi-donor trust fund
NEDA National Economic and Development Authority
NGO non-governmental public organization
NАТО North Atlantic Treaty Organization
ORDLO separate districts of Donetsk and Luhansk regions
UN United Nations
UNDP United Nations Development Program UNICEF-United
Nations Children›s Fund
USAID U.S.Agency forInternational Development

4
MILITARY-POLITICAL CONTEXT

In February-March 2014, the troops of the Russian Federation occupied the Autonomous Republic of Crimea
(ARC). In 2014-2015, the proxy forces of the Russian Federation, which later took the form of the unrecog-
nized Donetsk People’s Republic and Luhansk People’s Republic, as well as the regular army of the Russian
Federation, took control of the part of Donetsk and Luhansk regions (including Donetsk and Luhansk region-
al centers).
In 2014-2022, the effective control over the city of Sevastopol, the Autonomous Republic of Crimea and
certain districts of Donetsk and Luhansk regions (ORDLO) was exercised by the Russian Federation (in the
case of ORDLO through the proxy administrations of DPR and LPR).
On 24 February 2022, the Russian Federation launched an invasion of Ukraine from many directions. Active
hostilities have taken place in at least nine border regions of Ukraine and continue in at least five regions at
the time of writing this report. The entire range of conventional weapons available to the parties is used in
hostilities, resulting in significant destruction of civilian infrastructure, including housing, administrative build-
ings, medical, transport, energy infrastructure, etc. Some cities, such as Mariupol and Volnovakha, are almost
completely destroyed. In addition, missile attacks have affected almost all areas.
Given the volatile nature of the war, it is difficult to predict the needs and challenges facing Ukraine after its
end. The following can be stated:
• The Ukrainian government retains the legitimacy and ability to govern the state apparatus in the
currently controlled territory of Ukraine.
• In general, the rule of law is maintained, law enforcement agencies and courts are working;
• In the territories liberated from Russian troops, basic state and social functions are rapidly being
restored.
We can expect the above points to be true for all the territory controlled by the Ukrainian government
at the end of the war, regardless of whether it increases or decreases1. Post-war countries have signifi-
cant challenges related to the legitimacy, credibility and effectiveness of the state. Given the above, there is
reason to believe that post-war Ukraine will not have these challenges, or will have them to a lesser extent
than other post-war countries.
At the same time, Ukraine has suffered significant damage to housing and infrastructure, partial depop-
ulation of entire regions, and the destruction of production. In addition to impoverishing the population,
this has a negative impact on budget revenues, limiting the government’s ability to implement independent
recovery policies. This makes Ukraine similar not only to post-war countries, but also to countries that have
suffered significant natural disasters.

1 At the time of writing, the Russian Federation controls a significant part of the Donetsk and Luhansk oblasts, almost the entire Kherson oblast, and selected districts of the
Zaporizhia and Kharkiv oblasts.

5
TYPICAL FORMS OF ASSISTANCE

The economic dimension of post-conflict reconstruction usually includes tasks such as the distribution of aid,
the restoration of physical infrastructure and facilities, the restoration of social services, the creation of an
appropriate environment for private sector development and the implementation of basic structural reforms
for macroeconomic stability and sustainable growth.2
Accountability, competence and corruption risk management are key factors contributing to the integrity of the
post-war reconstruction process.
Accountability mechanisms mediate the social contract between citizens and the state. We are talking about
both formal accountability and local mechanisms to involve citizens, especially those who risk losing confi-
dence in rebuilding their country. Over the past two decades, tens of billions of dollars have been spent on
post-war reconstruction without accountability to the final beneficiaries. Information on aid in these coun-
tries is incomplete, opaque and often misleading.3
Post-war states are accountable both to their citizens and to their foreign financial and political supporters (the
latter, in turn, are accountable to their legislative oversight bodies, citizens). The link between the views of
donors and beneficiaries can be tenuous. The ability to manage the tensions and contradictions of this dual
system of responsibility is important for the post-war state.4
Accordingly, transparency and control of corruption risks in the context of standard forms of assistance
should be considered both in terms of accountability to aid beneficiaries domestically and to donors, in particular
international ones.
The analyzed experiences of countries recovering from wars or other disasters highlight the main typical
forms of assistance (measures) to achieve effective recovery objectives. Different forms of aid are character-
ized by different typical corruption risks.
It should be noted that the forms (measures) of assistance and their choice are determined by:
• areas in which recovery is taking place: industry, infrastructure, social facilities, housing, ecosystems,
defence sector, etc;
• types and degree of destruction, damage: complete destruction or partial damage to material objects,
loss of jobs, damage to health, environmental pollution (toxic substances, weapons dumps, shells, etc.),
environmental destruction (loss of forests, soil fertility, etc.);
• recovery policy objectives: e.g. renewable energy modernisation, energy efficiency; taking into account
sustainability and environmental objectives; reducing the impact of possible wars; correcting social imbal-
ances caused by the war; developing sectors that will renew the country’s long-term economic base;
• type of resources (financial, non-monetary);
• source of resources (state budget revenues, international aid, voluntary donations);
• subject of the benefit, private, public sector, individuals, ecosystems.

1. Forms of donor assistance

Also, the definition of instruments to control the acceptance, management and use of financial and non-mon-
etary resources of international and foreign donors is influenced by the form in which donors provide aid for
the reconstruction of the country. According to this criterion, the following forms of assistance can be
distinguished.
2 Post-Conflict Economic Reconstruction, Nikolaos Tzifakis: https://pesd.princeton.edu/node/586
3 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné http://www.gsdrc.org/docs/open/innovations-in-
accountability/ia7.pdf
4 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné
http://www.gsdrc.org/docs/open/innovations-in-accountability/ia7.pdf

6
1.1 Assistance to the budgets of war-torn countries
For financial assistance, it is important to be able to further track and verify the use of budget funding
for reconstruction.5 The World Bank’s (2022) Disaster Resilient and Responsive Public Financial Manage-
ment Assessment (DRR-PFM)6 refers to the availability of reliable, relevant and timely information on
funding allocation, procurement, implementation progress and contract management. The need to distinguish
elements or sub-accounts related to a disaster in its chart of accounts is noted. This may include parameters
for marking and tracking disaster-related costs for existing codes and programs used in emergencies.
Accelerated spending of public finances should take place within a framework of controls that can be
adapted to ensure timely responses to recovery needs without compromising the transparent and targeted
use of resources. The DRR-PFM contains recommendations on this issue, described in the “Corruption Risk
Management” section below.
In particular, one person or a small group should not be able to initiate, approve, implement and review the
same actions.The separation of functions is one of the most important features of an internal control plan to
reduce the risk of fraud or misappropriation.
Loans and grants (as a source of budget revenue)
Depending on the consequences of the disaster, governments may take out new loans or restructure existing
ones. Loans can be used to finance a specific project directly or as budgetary support to close the budget gap
as a result of reconstruction measures. The grants, which often accompany loans, can finance specific recon-
struction projects, other forms of technical assistance, and consulting services.
It is common practice for government bodies to approve such forms of assistance.
For example, in the Philippines, the National Economic and Development Administration approves:
• program-type loans or budget support;
• project loans - regardless of the amount;
• foreign grants, depending on the threshold (according to existing policies and guidelines).7
Also, the policies on the best time and the most effective way to solve a country’s debt
problems can be applied to loans to countries from the official sector to promote economic development.

1.2 Non-budget support (other)

At the initial stage of funding by foreign donors, funding goes largely to local authorities and community lead-
ers, as the state at the highest level cannot administer its use in a timely manner. Despite numerous studies
highlighting the issue, the state capacity building is a neglected aspect of reconstruction support. Where insti-
tutions are weak, the state is often bypassed. In Afghanistan, 75% of aid went outside the state budget. In Bos-
nia and Herzegovina, the figure was 80%. In Palestine, due to the Western boycott of the Hamas government,
Western aid after 2006 was almost entirely channeled through the president’s office, bypassing the elected
parliament.8

1.2.1 Direct targeting of aid to affected regions

Development partners, particularly international ones, can self-manage their own rehabilitation and recon-
struction assistance by directly implementing reconstruction projects in affected areas:
- provide assistance through local governments or civil society organizations;
- introduce public-private partnership. This allows them to work with the government on the specific com-
5 Expands an analytical tool first developed to support sustainability in nine Caribbean countries
6 Disaster Resilience and Responsive Public Finance Management: An Evaluation Tool, International Bank for Reconstruction and Development, World
Bank, 2022: https://openknowledge.worldbank.org/handle/10986/37033
7 Disaster rehabilitation and recovery planning guide of the National Economic and Development Administration in the Philippines (2020) https://
ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_DM130266
8 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf

7
plexities of rehabilitation and reconstruction, and encourages them to make long-term commitments to
projects.
The government must be able to balance assistance from partners and ensure government control over re-
habilitation and recovery programs. The government should require international agencies and development
partners to consolidate their recovery measures and coordinate closely with national or local governments.
The establishment of a coordination mechanism (channels, coordination structures) will facilitate and clarify
the role of each stakeholder. The government can also identify ways for partners to participate and clearly
specify protocols, roles, responsibilities and authorities.
Assisting partners may be involved in administrative coordination and financial management (or assis-
tance). This will help avoid duplication of help.9
Also, for an active role on the community development board, local leaders need access to information about
projects. The information is recognized as a key component of success in reconstruction. International aid
systems can be opaque. Recognizing the strategic value of information in Afghanistan, NATO’s International
Security Assistance Force (ISAF) has created a database of more than 45,000 reconstruction and develop-
ment projects across the country. They launched this initiative because no other agency - the Afghan govern-
ment, USAID, the World Bank or the UN - has created a reliable, comprehensive database10.

1.2.2 Joint projects with governments, including investment, public-private

partnerships
National or local authorities can cooperate with non-governmental organizations, the private sector and
development partners in implementing rehabilitation projects.
Such projects are usually subject to approval and reporting in the manner prescribed by law. Tools such as
formal arrangements, agreements, platforms, etc. are implemented to formalize cooperation agreements.
Existing programs (area, facilities, etc.) can be expanded, providing ready resources and rapid application of
interventions in the early recovery phase.
To mitigate delays in project implementation (slow procurement process, untimely use of funds and number
of staff needed), the government may contract a private company or international organization to carry out
specific rehabilitation activities.
An example is the Marawi Rehabilitation Project (Philippines) using a cost-sharing agreement between the
UN Program and the Social Housing Finance Corporation. The said project dealt only with certain types
of projects and did not include infrastructure projects. The recommendations are provided for this type of
project:
• clearly indicate which projects may be covered and which conditions are allowed by law:
• standardize parameters, in particular in terms of quality specifications and cost estimates.
The Philippines, through the Government Procurement Policy Board (GPPB), has issued an Instruction on the
use of the framework agreement.11
It should be noted that there is a World Bank guide for procurement specialists on the development, con-
clusion and implementation of framework agreements in the field of financing investment projects (2018)12.
Also, an example of a tool for cooperation between government and private, international donors is the Phil-
ippine Development Forum13 - a government mechanism for:
9 Disaster rehabilitation and recovery planning guide of the National Economic and Development Administration in the Philippines (2020) /https://
ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_DM130266
10 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf
11 Disaster rehabilitation and recovery planning guide of the National Economic and Development Administration in the Philippines (2020) :https://
ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_DM130266
12 Disaster rehabilitation and recovery planning guide of the National Economic and Development Administration in the Philippines (2020) :https://
ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_DM130266
13 Disaster rehabilitation and recovery planning guide of the National Economic and Development Administration in the Philippines (2020) :https://
ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_DM130266

8
• promoting political dialogue between stakeholders on the country’s development agenda;
• forming commitments between different stakeholders on reform agenda items.

The coordination of assistance projects is important for this type of assistance. Sometimes line ministries
submit proposals directly to donors. Donors may not take national priorities into account.

Donor-established coordination mechanisms can fail in practice. Some large donors ignore the coordination
system altogether. At the same time, the right of recipients to say “no” to projects that duplicate existing
efforts or exceed their capabilities is also important.14
1.2.3 Multi-donor trust fund
Multi-donor trust fund (MDTF) involves the participation and pooling of resources of different partners on
a single set of agreed conditions, goals, objectives. The pooled funds are managed by a trustee and through a
supervisory structure.The access to and approval of such funds is subject to the terms of the fund agreement.
For example,Typhoon Yolanda MDTF was set up by the Asian Development Bank (ADB) as a trustee for con-
tributions from the EU, ADB and the UK Department for International Development (UK).
Yolanda MDTF’s tasks included: providing technical assistance, financing the urgent needs of construction and
reconstruction, co-financing projects of other partner organizations.
To gain access to this MDTF, implementing agencies submit a project proposal for approval to the Steering
Committee, which consists of the Department of Finance (Chief) and the oversight agencies (National De-
partment of Economy and Development, Department of Budget and Administration and the Office of the
Assistant President for Rehabilitation and Restoration), as well as development partners (with a minimum
contribution of $ 5 million) as members.15

1.2.4 Humanitarian aid

Humanitarian aid is usually provided by bilateral, multilateral and international partners and is channeled
through the national government, local authorities, non-governmental organizations, the private sector or
scientific institutions.
As a rule, the management of material values has lower corruption risks than the management of funds. If aid
is provided in forms that make it less fungible and less susceptible to corruption, it is likely to have a greater
impact on growth. In favourable political environments, where corruption is low, the impact of humanitarian
growth is less pronounced.16
The Philippine Disaster Risk Reduction and Management Act of 2010 17 provides for criminal liability and
fines for the following violations of the rules for the distribution of technology, tools, equipment, disaster
management teams/experts:
• preventing their entry, spread to affected areas;
• purchase for consumption or resale;
• sale, compulsory seizure;
• readdressing, misdelivery (to persons other than the rightful recipient, the consignee);
• acceptance, possession, use or disposal by a person to whom they are not assigned;
• false information about the source of the assistance (changing labels, repackaging, verbal statements);
14 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf
15 Asian Development Bank, establishing the Typhoon Yolanda Multi-Donor Trust Fund (2014): https://www.adb.org/sites/default/files/institutional-docu-
ment/59679/establishing-typhoon-yolanda-multi-donor-trust-funds.pdf
16 Post-conflict recovery and peacebuilding (2011) Anke Hoeffler, Syeda Shahbano Ijaz, Sarah von Billerbeck: http://web.worldbank.org/archive/web-
site01306/web/pdf/wdr%20background%20paper_hoeffler%20et%20al_04dbd.pdf
17 https://www.officialgazette.gov.ph/2010/05/27/republic-act-no-10121/

9
• replacing the same items with lower quality, cheaper items;
• illegal request from authorized persons or organizations;
• deliberate use of false, exaggerated data in a request for goods assistance.

1.2.5 Donations
Development partners, non-governmental organizations, private companies and individuals can provide
cash or in-kind donations as a form of assistance to disaster-affected regions. Some companies and usually
non-governmental organizations set up corporate social responsibility funds to collect donations. Like the
MDTF, there are also private sector multi-donor funds.
The national agencies receiving donations are normally governed by guidelines on the acceptance and pro-
cessing of donations and are subject to accounting, reporting and auditing for this type of funds. In particular,
this approach is described in the National Economic and Development Administration’s Disaster Recovery
Guide (2020)18.
1.2.6 Grants19

Risks for this type of aid relate to a lack of coordination, transparency, accountability.

For example, government departments, NGOs working in high priority sectors (education, rehabilitation,
health) are sometimes offered more funding than they can absorb. There is a high risk, however, that some
recipients may accept or attempt to fund the same project more than once, diverting additional funding for
other, sometimes personal, benefits. As a condition of receiving grants, the obligation of grant recipients to
report each grant to an independent registry is specified.20 At the same time, there is a risk of misuse of funds
by the financing providers themselves due to the frequent lack of strict controls over the transparency of
procedures, or conversely, lack of transparency associated with an overly bureaucratic and closed selection
process for contractors, leading to artificial restrictions on competition and distorted results.

1.2.7 Technical assistance, human capital development programs

One aspect of transparency is that donors have the information they need to understand the local context.
Thus, one of the risks of international aid is called an unintended effect that damages the skills of local resi-
dents. For example, in Kosovo, donors often complained about the lack of appropriate local partners in the
early phase of reconstruction. Instead of working with these local competences, they competed to attract
the most qualified local staff (offering salaries much higher than in the public and even private sector). This
created an artificial, temporarily inflated labor market for certain professions.
This approach:
• drains both public and private employment markets of skilled workers;
• instead of strengthening local competencies, it weakens them.
It is important to develop the human capital of the recipient country through train-
ing programs related to the reconstruction of the health, education and employment
sectors.21

18 https://ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_
DM130266
19 Monetary or other funds donated (free of charge and without refund) by citizens, legal persons (including foreign ones), and international organisa-
tions for specific purposes under conditions provided by the grantor (https://uk.wikipedia.org/wiki/%D0%93%D1%80%D0%B0%D0%BD%D1%82).

20 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf
21 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf

10
2. Forms of assistance to beneficiaries
In the countries whose experiences have been analyzed, these typical forms of assistance (measures) for the
private or public sector in rebuilding the destruction caused by wars, other disasters have been encountered.

2.1 Cash assistance programs for the population

The government’s existing nationwide cash transfer programs for poverty alleviation can be used as a tool for
implementing disaster cash transfer programs.
Using the existing system of identifying beneficiaries and providing assistance facilitates immediate assistance
to affected families and individuals. The program can be conditional or unconditional depending on the na-
ture of the intervention, the context of the disaster and the urgency of the need. Disaster-related funding
requirements and arrangements can be developed and adopted based on the mechanisms and systems of the
existing cash transfer program.22
This approach may be more effective if money is spent domestically on certain types of goods and services
that have a higher multiplier and stimulate economic recovery.This mechanism can also be used to encourage
the return of citizens who have left the country.
For example, the NGO Peace Dividend Trust23 promotes a “just peace dividend” approach to economic recov-
ery projects. It involves the international community using local goods and services for its operations. It creates
jobs, generates important tax revenues and develops a local market that maintains peace and long-term stability.

2.2 “Cash for Work” Program

The program can be funded and/or implemented by the government, a donor agency or a non-governmental
organization that creates temporary jobs for people. This is a short-term intervention providing monetary
assistance in exchange for services, including reconstruction. It has been used in various middle- and low-in-
come countries. The results are short-term jobs, increased income and consumption of the population, res-
toration of infrastructure, and involvement of people in development activities in their own communities.
The recommendations on “Cash for Work” implementation and the post-conflict recovery process (Sri Lan-
ka, 2009)24 include:
• holding community meetings to determine the priorities of the projects included in the program;
• delineating the roles and responsibilities of different agencies at different levels of government;
• third party supervision, social and technical audit;
• a monitoring and evaluation plan to determine whether the program is achieving its objectives and
meeting the needs of clients and the community.
From the very beginning, it is important to control the time flow: input data (quantity and quality), interme-
diate results and final results. For successful monitoring, it is important to indicate the indicators to be mon-
itored and measured for all three elements.

2.3 Assistance in the reconstruction/construction of housing and other facilities de-

stroyed by the disaster
For example, the “Marawi Recovery through Housing and Livelihood Support Project” (Philippines) was
implemented using a cost-sharing agreement between the UN Human Settlements Program and the So-
cial Housing Finance Corporation. The cooperation components included, inter alia, the construction of

22 Disaster rehabilitation and recovery planning guide of the National Economic and Development Administration in the Philippines (2020) :/https://
ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_DM130266
23 https://www.devex.com/organizations/peace-dividend-trust-pdt-41493
24 Guidelines for Implementation of Cash for Work -A Post Conflict Recovery Process (2009) https://www.researchgate.net/publication/253330586_
Guidelines_for_Implementation_of_Cash_for_Work_-A_Post_Conflict_Recovery_Process

11
1,500 permanent housing units for affected households, ten (10) units of communal infrastructure.25 Social
responsibility approaches need to be combined with spot checks, audits and a reliable sanctions regime to
effectively curb corruption.
In Nepal, for example, an innovative energy program providing hundreds of remote villages with solar panels
and micro-hydropower plants sends private auditors to a random sample of about 20% of the villages. When
contractors’ fraud is discovered, a “fine” of more than five times the cost of the project is imposed. Only a
fifth of the villages have been audited. Contractors or communities that refuse to pay a fine are blacklisted. As
a result, the level of fraud in this program was independently tested and very low.
It is noted that such a system of fines or sanctions is a rarity in post-war assistance. Most donors prefer to
quietly withdraw their support if fraud is detected.26
2.4 Granting soft loans, loans, other banking services
The Philippines Disaster Risk Reduction and Management Act of 201027, for example, provides a recovery
measure - the provision of interest-free loans by government financial or credit institutions to the most af-
fected populations through their cooperatives or people’s organizations.
2.5 Investing, including in job-creating production units
The Disaster rehabilitation and recovery planning guide of the National Economic and Development Admin-
istration in the Philippines (2020) provides recommendations for inclusion in rehabilitation programs and
recovery of the investment program. Its further update (based on an assessment of physical and financial
achievements compared to the current situation) is also proposed. The emphasis is placed on the usefulness
of program monitoring reports.

The above list is not exhaustive. The sources describing the experiences of countries recovering from disas-
ters mention, for example, assistance such as:
• compensation for losses (partial or complete) to individuals, the private sector;
• providing materials for the restoration of damaged objects (including at regulated prices);
• free issuance of permits, for example for construction, access to electricity, heat and water supply
networks;
• demining of the territory;
• free clearing of territories and garbage removal;
• financing the restoration of physical and psychological health;
• economic reintegration into society of certain categories, such as internally displaced persons, demo-
bilized ex-combatants;
• financing of environmental cleaning projects, elimination of dangerous situations.

25 Disaster rehabilitation and recovery planning guide of the National Economic and Development Administration in the Philippines (2020) :/https://
ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_DM130266
26 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf
27 Republic of the Philippines Act No. 10121 https://www.officialgazette.gov.ph/2010/05/27/republic-act-no-10121/

12
Conclusion:
Summarizing the international experience outlined in this section, the key role of transparency and corrup-
tion risk management for all types of aid should be noted. It is also important to strengthen the state’s capac-
ity to make effective use of post-disaster recovery funding.
Different types of aid may be characterized by different types of risks and appropriate management and trans-
parency instruments. They should be seen both in terms of accountability to in-country beneficiaries and to
international and other donors.
A feature of the risks associated with post-disaster aid budgets is the accelerated spending of public financ-
es. Monitoring mechanisms should be adapted to respond to recovery needs in a timely manner without
compromising the transparent and targeted use of funds.
When donors send aid directly to affected regions, the ability of the government to balance and coordinate
such aid and to have control over reconstruction programs is important. Governments can put forward
requirements to consolidate donor efforts, coordinate them with national governments, and establish coor-
dination mechanisms.
Common donor projects with governments are normally subject to approval, coordination and reporting as
defined by law.
Coordination and accountability are also needed for grants.
The access to multi-donor trust funds is subject to control, including approval by the funds’ steering commit-
tees of project proposals by implementers.
Regulatory procedures for recording, processing, reporting, monitoring donations, humanitarian aid and ac-
countability for violations are also applied.
It is important for donors to have sufficient information to understand the local context.
Effective implementation of cash assistance programs, “Cash for Work”, reconstruction assistance, and other
forms of assistance to final beneficiaries need to be discussed with communities; regulatory guidelines and
parameters; separation of roles and responsibilities; supervision, monitoring and evaluation of the achieve-
ment of program objectives.

13
CORRUPTION RISKS

“Corruption is the abuse of entrusted power for personal gain.”28

“Active or passive misuse of the powers of public officials (appointed or elected) for private financial or other
benefits”.29
In legal terms, corrupt practices are only those that are explicitly prohibited by laws and other regulatory le-
gal acts. But the broader definitions include not only unlawful acts, but also what most citizens consider to be
corrupt and unethical behaviour that violates the norms and rules of public life. Corruption, the intertwining
of public functions and private interests, violates the basic principle of impartiality and affects the quality and
results of government decisions. The risk of a very limited definition of corruption is that in any community
there may be a misconception that this phenomenon does not affect everyone.30

The most common types of corruption are:

• Bribery of an official is a proposal or promise of illegal benefit, or the actual provision of such benefit
for the actions of an official or his inaction with the use of his powers.
• Abuse of power is an illegal use of power by a person endowed with power or official authority in
order to obtain any illegal benefit.
• A conflict of interest is a person’s personal interest in the area in which he or she exercises his or
her authority, which may or may not affect the objectivity or impartiality of his or her decision-making, or
whether or not he or she acts in the exercise of such authority.
• Embezzlement is the wrong, misappropriation of entrusted (public) funds or their misappropriation
for personal use.
• Nepotism, cronyism, patronage - giving preference to relatives, friends or supporters in the perfor-
mance of public duties.
• “Service for service” (Quid pro quo) is a Latin phrase that means “something for something” and
often involves the exchange of goods, services or other values. This is not unacceptable, but can be used
with corruption.
• Illegal influence is a situation when someone uses his/her authority to influence another person or
legal decision in a direction that may be contrary to the public interest.

Fighting corruption in a post-conflict environment is a major challenge, given that after military conflicts,
preference is given to peacebuilding and restoring stability, while corruption can be ignored altogether. Many
post-conflict countries are considered the most corrupt in the world. Given the volatile situation in post-con-
flict countries, concerning both the political situation and the possible military threat, as well as the lack of
transparent reporting, this creates an environment conducive to corruption.

It should also be borne in mind that corruption and mismanagement of the economy can further worsen the
conditions for the population and business, which can lead to internal unrest and anger at the government.
Corruption risk is the probability that a corruption offense or a corruption-related offense will occur that
will adversely affect the achievement of certain goals and objectives by the authority31.

28 Transparen cy International
29 Organisation for Economic Co-operation and Development — OECD
30 A guide with recommendations on transparency and prevention of corruption risks at all stages of the establishment and operation of the Administra-
tive Services Center, prepared under the international program “U-LEAD with Europe”, funded by the European Union and its member states Denmark,
Estonia, Germany, Poland and Sweden.https://tsnap.ulead.org.ua/wp-content/uploads/2020/11/U-LEAD-Anti-Corruption_Manual-2020.pdf
31 Methodology for assessing corruption risks in government activities https://zakon.rada.gov.ua/laws/show/z1718-16#n13

14
32

Corruption risks exist at all stages of the project. They reach a peak at the implementation stage, when large
sums of money can pass from hand to hand.

Stage 1 Concept
Corruption risks at this stage relate to decisions that may have a direct impact on stakeholders, setting goals
and areas of assistance. The interests of the partners and their willingness to monitor the development of
the project may influence the determination of the amount of assistance. When project appraisals are passed
on to consultants, it increases the risk of fraudulent appraisals and bribery. Political maneuvers (for example,
in favor of certain groups), bribes and kickbacks, as well as conflicts of interest also take place at this stage.
The concept phase is crucial for the initial identification and assessment of corruption risks, including the
analysis of political economy to take into account the impact of the assistance program.

Stage 2 Development
The development phase involves corruption risks, when, for example, the terms of reference specify the list
of beneficiaries and partners. Other risks include budget manipulation, fuzzy criteria and asymmetric infor-
mation. In addition, the partner selection process is vulnerable to unethical practices: bribery, conflicts of
interest, and etc.

Stage 3 Implementation
At this stage, activities such as recruitment and procurement take place, leading to a peak in payments. This is
why there is a greater risk that the attracted subjects will be involved in various corrupt activities.These risks
can be fiduciary (fraud, theft), reputational, operational, legal and compliance, etc. For example, asset manage-
ment, licenses and access to services, procurement are common sources of corruption risks.

Stage 4 Termination
The termination stage is not insured against corruption risks. Abuse can occur due to a significant need (or
32 https://www.u4.no/topics/corruption-risk-management/basics

15
desire) to pay the rest. Post-contract activities can increase the impact of pressure and opportunistic be-
havior. Once accounts are closed, irregularities such as falsified results in documents and reports, collusion
between program managers and evaluators or auditors, falsified estimates of results, etc. may be discovered.

International financial organizations (“IFOs”) provide a significant share of external investment in Ukraine. As
it is considered a high-risk country for business, IFOs apply special conditions to their investments and bor-
rowings, which include in particular a commitment to raise anti-bribery standards for Ukrainian beneficiaries
responsible for the implementation of funded projects.The peculiarity of this expansion is that MFOs require
some Ukrainian authorities and state-owned enterprises to update compliance systems in accordance with
world best practices that exceed the standards of Ukrainian legislation33. Such applicable standards are:
• ISO 37001 “Anti-Corruption Management Systems”,
• Transparency International’s anti-bribery business principles
• 10 anti-corruption principles of Transparency International for state-owned enterprises,
• OECD guidelines for combating corruption in state-owned enterprises.

The requirement of MFIs to apply best practice to the public sector stems from the need to:
• apply elements of the compliance system that are not implemented in national legislation and regu-
lations and are therefore not considered mandatory and necessary by the authorities and state-owned
enterprises;
• introduce detailed guidance on legally enforced compliance elements;
• promote the development of compliance culture.

A very important and widely discussed event was the adoption and entry into force of the ISO 37001 Stan-
dard, which established a single international standard of anti-corruption compliance in business. On the one
hand, the document is often criticized, noting that the conditions for the existence of different businesses in
different countries are so different that the existence of any standard in this area is currently incorrect. On
the other hand, for companies established and operating in countries with economies in transition, this stan-
dard is an excellent guide for developing and implementing their own anti-corruption program, a “hint” both
on its structure and on the content of individual measures to be implemented.34

Natural disaster situations have some typical characteristics35:

• Large natural disasters are often accompanied by large-scale regional or global humanitarian disasters.
• Humanitarian aid is often realized because of sudden and huge donations of money: millions or billions
of dollars are earmarked for immediate and long-term assistance. In addition, the need for large-scale
reconstruction, which is the result of mass destruction, creates significant economic opportunities for
potential suppliers and contractors, as well as the influx of goods and service providers.
• The governments of the affected countries and aid agencies are under enormous pressure for quick
help, especially immediately after the disaster. These characteristics of natural disasters potentially con-
tribute to the risks and opportunities for corruption and mismanagement during relief operations and
further rehabilitation and reconstruction, namely:
• Sudden and massive inflows of money, goods or services increase opportunities for mismanagement,
33 https://yur-gazeta.com/publications/practice/korporativne-pravo-ma/globalniy-vpliv-na-aktualni-trendi-komplaens-v-ukrayini.html

34 https://cgpa.com.ua/wp-content/uploads/2018/07/Compliance.pdf
35 https://baselgovernance.org/sites/default/files/2019-01/Corruption%20in%20natural%20disaster%20situations.pdf

16
 distraction and corruption. The enormous financial and material assistance involved is a great temptation
for those who have access to it. Implicated actors might reason that diversion will be less noticeable the
more money and goods are involved. In this way, there may be fewer obstacles to engaging in corrupt
practices, and at the same time, the money that can be made through corruption is multiplied.
• The urgent need for an ambulance can lead to an incorrect assessment of need. Which leads to poor
targeting, excessive or insufficient supply of aid, or the launching of an inappropriate project, create op-
portunities for exploitation.
• The need for rapid funding of recovery and coping measures can easily lead to a tendency to circum-
vent standard procedures, including procurement rules such as genuine competition and transparency of
contract allocation.
• There is usually an asymmetrical relationship between beneficiaries, who are economically and polit-
ically weak and dependent on external aid, and aid agencies and donors, who mostly act voluntarily. Hu-
manitarian aid mainly consists of a one-way transfer of resources, during which aid recipients have no
authority to monitor the activities of the aid providers. This imbalance of power can lead to low levels of
transparency and accountability in disaster-affected populations, which in turn increases the opportunities
for corruption.
• The humanitarian aid system is highly competitive, and not very different from any other business in
this respect. If disaster strikes, there are numerous aid providers willing to provide their services, as long
as donors are willing to fund them. Such competition can also lead to choices being made to enhance
one’s organizational reputation rather than based on a proper needs assessment, which must be qualified
as an indirect misuse of funds.
• Lack of coordination between donor organizations, aid providers, government agencies, civil society
organizations and private contractors can lead to double funding for the same project.
• The following types of corruption can arise in the provision of reconstruction and humanitarian assis-
tance to affected countries:
• fraud,
• theft of assets, humanitarian aid,
• unfair distribution of aid resources;
• bribery.
In disaster response, the priority is to save lives and restore basic services for human livelihoods. At this
stage, the necessary humanitarian aid may be inequitably distributed, resulting in the need for partial procure-
ment. In general, the inaccessibility of all victims to humanitarian assistance can lead to the marginalization of
individual communities.
The subsequent medium- and long-term phases of reconstruction encompass rebuilding livelihoods and com-
munities, rebuilding destroyed infrastructure and focusing on long-term economic development. All phases
are prone to various forms of corruption, and primarily harm the people, most affected by the disaster.
At the reconstruction stage, the main corruption risks relate to attempts to circumvent procurement and
contracting procedures. Inappropriate planning and contracting in favour of a group of interests can lead to
inappropriate or poor-quality infrastructure. As a result, the real needs of affected people and their safety are
ignored in favour of personal gain.36
Classification of corruption risks
By category, corruption risks can be37:
• external (the likelihood of corruption risks occurring is not related to the performance of the au-
36 https://baselgovernance.org/sites/default/files/2019-01/Corruption%20in%20natural%20disaster%20situations.pdf  
37 https://wiki.nazk.gov.ua/category/organizatsiya-roboty-upovnovazhenyh/koruptsijni-ryzyky-ta-antykoruptsijni-programy/1-antykoruptsijna-programa-or-
ganiv-vlady/normatyvni-osnovy-1-antykoruptsijna-programa-organiv-vlady/

17
 thority’s relevant functions and tasks);
• internal (the likelihood of corruption risks arising is directly related to the organizational and manage-
ment activities in the authority, in accordance with its assigned functions and tasks).
• By types, corruption risks can be:
• normative-legal (absence, contradiction or unclear regulation in the legislation of provisions on per-
formance by the authority of functions and tasks);
• organizational (uncertainty or unclear definition of procedures for the authority to perform functions
and tasks);
• personnel;
• financial and economic;
• administrative;
• control and supervision, etc.
The form of corruption that arises during disaster relief and recovery varies depending on the participants involved.

1. Public authorities.
Public officials have great potential for both anti-corruption measures and abuse. For example, it may be
established that funds are distributed only by central government. In this case, without additional oversight
of the distribution of funds, some officials may abuse their power to provide assistance or demand bribes to
receive assistance. There is a high probability of corruption risks at the land allocation stage, e.g. for the pro-
vision of shelters for disaster victims. Also, at state level, public procurement procedures for renovation work
could be simplified to ensure rapid renovation. However, this would create the conditions for the commission
of violations, in particular embezzlement or misappropriation of property. It should also be noted that in the
case of non-competitive procurement procedures, this calls into question the quality of the goods/services
concerned and generally the achievement of the ultimate purpose for which the procurement was made.38

2. Donor organizations providing assistance.

This can include domestic NGOs and civil society groups directly implementing their own projects or work-
ing as implementing partners for international aid agencies, foreign bilateral government aid agencies, foreign
non-governmental development organizations and international organizations such as UNDP, UNICEF or the
World Bank. Most of them act either as donors funding relief and recovery projects or as implementers of
aid; some may be both donors and implementers. The corruption risks they face differ depending on their
roles in a given situation.
Aid organizations can deceive donors by, for example, underwriting receipts for aid that have not actually
been received and have been used to support expense claims. They can also “inflate” costs or contingencies
in their budgets. Donors can bribe donor representatives, in particular for funding.
Unethical management staff may try to obtain financial support for the same project from two or more do-
nors, resulting in double funding. Unknown persons may raise funds among donor communities, seemingly
to help disaster victims, when in fact they are so-called “fake NGOs” – fake organizations. The victims of this
form of fraud are often individual donors, because they do not have the means to verify the true nature of
the fundraising organization.
Individuals in implementing organizations could budget for “ghostly staff” and transfer wages to their own
accounts. Project managers may falsify monitoring or evaluation reports to conceal evidence of corruption.39

3. Contractors and suppliers.

The area of procurement procedures has high corruption risks, as noted earlier. Given that huge sums of
reconstruction contracts can be involved, there is considerable potential for collusion with bidders, procure-
38 https://baselgovernance.org/sites/default/files/2019-01/Corruption%20in%20natural%20disaster%20situations.pdf
39 https://baselgovernance.org/sites/default/files/2019-01/Corruption%20in%20natural%20disaster%20situations.pdf

18
ment authorities and donors offering kickbacks. The contractors can also provide poor infrastructure, using
lower quality and lower cost materials than budgeted, to keep the difference to themselves. A typical example
is the use of diluted cement by designers. Regarding the supply of goods, an example would be the distribution
of expired medicines or foodstuffs. The use of substandard materials can also involve bribing inspection au-
thorities to accept work done, which can lead to dangerous consequences for the beneficiaries, for example
if structures subsequently collapse.40  
4. Persons in the affected areas and final beneficiaries
Local people - whether intended beneficiaries or local actors who are not affected - can also take advantage
of the complexity and opportunities of post-disaster situations. Community leaders may offer bribes to gov-
ernment or humanitarian organizations to gain support for the distribution of aid or otherwise gain support
for their own interests. Local politicians may want to provide assistance only in areas where they can count
on the popularity and support of their party.
Local elites can manipulate the list of recipients who need help.41

The areas at the level of local authorities that are most vulnerable to corruption have been identified in in-
ternational studies42:
• Procurement (counterfeit bidding, bribery, favoritism, “kickbacks”);
• Payments (e.g. bribes, kickbacks/commissions)
• Payment of fees and taxes (incentives to avoid payment, falsified records, embezzlement of funds);
• inspections and investigations (paying bribes to “turn a blind eye” to inspections on certain issues,
forged inspection reports, etc.)
• Licenses and permits (bribes for issuing licenses, checking business activities, etc.);
• Construction and development of infrastructure (use of cheaper materials, falsified purchases, inap-
propriate works, commissions/ “kickbacks”)43.

Factors at the local level that affect the level of corruption:

• community size;
• features of the socio-cultural context;
• close family ties;
• low activity of local media and weakness of civil society;
• dishonesty of political leadership;
• insufficient potential (institutional, personnel, financial, material) for the effective implementation of
the necessary anti-corruption procedures.

40 https://baselgovernance.org/sites/default/files/2019-01/Corruption%20in%20natural%20disaster%20situations.pdf
41 https://baselgovernance.org/sites/default/files/2019-01/Corruption%20in%20natural%20disaster%20situations.pdf
42 A guide with recommendations on transparency and prevention of corruption risks at all stages of the establishment and operation of the Administra-
tive Services Center, prepared under the international program “U-LEAD with Europe”, funded by the European Union and its member states Denmark,
Estonia, Germany, Poland and Sweden.https://tsnap.ulead.org.ua/wp-content/uploads/2020/11/U-LEAD-Anti-Corruption_Manual-2020.pdf
43 According to the authors, factors such as misuse of funds; distortion of financial statements; overestimation of estimates; delayed or non-performance
of work; poor quality of work; and misappropriation of funds can also be added.

19
Conclusion:
Corruption is a complex phenomenon that has many manifestations, including in the recovery process. Cor-
ruption risks have different classifications described in the section.
Each participant in the relationship (public authorities, donors, suppliers, victims) has inherent corruption
risks in his participation.
Recovery situations have typical characteristics (speed, increase in funding, etc.) that increase the risk of cor-
ruption. This creates a risk of ignoring the real needs of the affected people for personal gain.
The key areas of corruption at the local level (procurement, payments, taxes and fees, inspections, licenses and
permits, infrastructure projects) and the factors that affect them are well researched.

20
MAIN STAGES OF RECOVERY AND THE CORRESPONDING RISKS

Post-conflict reconstruction is a holistic and multidimensional process that includes efforts to restore law
and order, improve governance, economic (rehabilitation and development) and social conditions (justice).44
Most disasters, regardless of their causes, lead to a process of recovery with recognizable phases, including
stages of rescue, assessment and restoration of critical infrastructure, reconstruction. Each contribution and
project should be planned according to priorities and synchronized with the relevant recovery phase. The
speed of the whole process depends on the level of pre-war prosperity, the nature of the damage and the
quality of reconstruction management.45
Summarizing the experience of other countries, we can highlight the approximate stages of the process of
rebuilding destruction due to wars or other disasters. Each of them has specific risks that require the use of
appropriate tools for transparency and control of corruption risks.
It should be noted that studies on the topic suggest that local accountability mechanisms that existed prior
to the start of the reconstruction process can be used and expanded from the initial stages. Accountability
based on existing local systems can be established fairly quickly.46
The following steps are selected on the basis of a study of the experience of post-war reconstruction of the
countries, set out in the sources cited in the references to this section.

1. Gathering information on damage, other damaging effects, estimating the extent of

damage
At this stage, the risks may be associated with the accuracy of documenting the fact and the extent of de-
struction, the correctness of determining the amount of damage for each fact.
For example, the Philippine Disaster Risk Reduction and Management Act of 201047 criminalizes the intentional
use of false and inflated data to support a request for funding, assistance, or relief goods.

Avoiding mistakes and corruption risks at this stage is important, as it is the starting point for identifying
needs and relevant budgetary and other resources that need to be mobilized for recovery, as well as for co-
ordinating local and international assistance.
Revision, recovery budgeting refers to the results of a disaster needs assessment (provides an initial as-
sessment of necessary interventions) or a rapid assessment of disaster losses. This is stated in the Disaster
Rehabilitation Guide of the National Economic and Development Administration of the Philippines (2020)48.
It also notes the importance of basing the damage assessment on an internationally recognized post-disaster
assessment methodology.

In the case of armed conflict, the Guide recommends the use of assessment methodologies specifically for
this type of disaster, as in addition to losses and damages, they include an assessment of social reconciliation
needs.
It can be assumed that unlike many military conflicts in recent years, which have been taken into account in
the methodologies, in Ukraine the issues of internal conflict that require the development of reconciliation
will not be as relevant.

44 Post-Conflict Economic Reconstruction, Nikolaos Tzifakis: https://pesd.princeton.edu/node/586

45 Post-war Reconstruction: Concerns, Models and Approaches, Jon Calame: https://core.ac.uk/download/pdf/56704076.pdf
46 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/
docs/open/innovations-in-accountability/ia7.pdf
47 https://www.officialgazette.gov.ph/2010/05/27/republic-act-no-10121/
48 https://ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_
DM130266

21
Also, taking into account the experience of planning and rapid assessment of losses from the negative con-
sequences of the disaster in the port of Beirut (Lebanon), which occurred in 2020, shows that the primary
and effective element of risk management is damage assessment, transparent planning of funds for timely
infrastructure rehabilitation49.This is a guarantee of efficient and targeted use of funds in accordance with the
needs of the affected country and a prerequisite for reducing corruption risks.
It should also be noted that the Office for the Coordination of Humanitarian Affairs within the United Na-
tions Secretariat (OCHA) provides links on its website50 to a number of tools and recommendations to
support and strengthen coordinated assessments and analysis of needs in humanitarian contexts.

2. Defining the goals and priorities of the recovery plan

This includes the proper consideration of all areas requiring recovery51, as well as the relevance of objectives
and priorities to current needs and available resources.
For example, the Iranian authorities focused on immediate relief and reconstruction of the economy and
army, while the international community failed to monitor the environmental consequences of the Iran-Iraq
war. As a result, some of the environmental effects now being seen in southern Iran can be partly attributed
to war.
Also, in Iran, various political groups sought to have their own social and economic plans, reflected in the
reconstruction strategy.The approaches of conservative factions to focusing on strengthening market mecha-
nisms, privatization and trade liberalization have become dominant in official policy.The issue of social justice,
which concerned only the most radical faction of the government, was not taken into account.52
Investment in judicial reform is usually one of the lowest priorities for reconstruction assistance. The experi-
ence of Afghanistan shows that this can come at a high cost - because the official legal system has not worked,
Afghans are returning to the traditional justice system (Islamic courts).53
The reviews of selected recovery measures in post-war Coventry (England) and Dubrovnik (Croatia) show
that successful short-term responses to post-war reconstruction do not always transform into successful
long-term development strategies.54

Accountability mechanisms can help policy makers in one of their most difficult tasks – prioritizing reforms
and projects.

They can also attract and empower citizens who otherwise risk losing confidence in the recovery process.55
In particular, researchers of disaster recovery note that information is often more valuable than money. Avail-
able methods and technologies of information transfer allow local recovery officials to develop a more effec-
tive strategy and constantly find sources of support.56

3. Defining tasks for the restoration of industries, territories

Due to the fact that the defined policy of the intervention authorities on reconstruction or the tools of
49 https://reliefweb.int/sites/reliefweb.int/files/resources/BeirutRapidDamageandNeedsAssessmentAugust2020EN.pdf
50 https://www.unocha.org/themes/needs-assessment-and-analysis
51 https://archive.unu.edu/unupress/unupbooks/uu21le/uu21le0e.htm
52 Long Road to Recovery: Community Responses to Industrial Disaster, James K. Mitchell, https://archive.unu.edu/unupress/unupbooks/uu21le/uu-
21le0e.htm
53 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf
54 Post-war Reconstruction: Concerns, Models and Approaches, Jon Calame: https://core.ac.uk/download/pdf/56704076.pdf
55 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf
56 Post-war Reconstruction: Concerns, Models and Approaches, Jon Calame: https://core.ac.uk/download/pdf/56704076.pdf

22
reconstruction are not strictly applied, the projects can be carried out unsystematically, without general plan-
ning or coordination.
Quality management includes careful conceptualization of community needs and project objectives, providing
a permanent structure for joint decision-making and management, research and presentation of all available
recovery options, development of additional and flexible budgets that take into account the volatile, inflation-
ary economic conditions.57
The National Economic and Development Administration’s Disaster Recovery Guide (2020)58 also strongly
recommends a bottom-up approach to the preparation of rehabilitation and recovery programs at all
levels. This will facilitate the significant participation of all stakeholders. Affected communities, NGOs and
the private sector, among others, should be consulted during the formulation of the program to ensure that
people›s hopes and aspirations have been taken into account, as well as to build confidence in government
action.

4. Identifying and attracting sources of funding and other forms of assistance

When choosing a source of resources for recovery, it is necessary to weigh in terms of their potential to
cause dependence, undesirable control over the country’s development and uneven development.
Donor’s trade and geostrategic interests play an important role in aid distribution.59
Another aspect that researchers are paying attention to is the common practice of international non-gov-
ernmental organizations receiving hundreds of millions of dollars for the vast majority of reconstruction
tasks. Much of this money is not distributed through government channels and is not even spent within the
countries concerned. Foreign contractors are occasionally accused of being unaccountable, corrupt and wast-
ing precious resources in rebuilding war-torn countries.60
The Bosnian case also showed that serious coordination problems can arise when several donors are in-
volved in reconstruction and each of them determines their own aid programs.61
It is also important not to ignore local mechanisms to manage the situation, as this can undermine local pow-
er and create a shaky dependence on foreign aid.62
5. Identification of measures to restore certain facilities and timelines
At this stage there may be corruption risks associated with taking recovery priorities, goals, objectives into
account when determining measures and timelines. For example, whether a particular facility is to be repaired
or rebuilt, dismantled, includes refurbishment goals for modernization, energy efficiency, ecology, etc.
This may include, but is not limited to, assigning the object of restoration to certain categories, such as: prompt
temporary restoration of destroyed objects; rapid reconstruction of infrastructure; comprehensive recovery.
It is important that the definition of answers to these questions is legally regulated.
For example, the long-term goals of disaster recovery in the Philippines include the principle of “build bet-
ter”.That is, reconstruction involves not only the restoration of pre-disaster conditions, but also a higher level
of sustainability standards, climate change and mitigation measures.63

It should be noted that the Sendai Framework for Disaster Risk Reduction 2015-203064 emphasizes that the
recovery phase was an opportunity to “build back better”:

57 Post-war Reconstruction: Concerns, Models and Approaches, Jon Calame: https://core.ac.uk/download/pdf/56704076.pdf

58 https://ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_
DM130266
59 Post-conflict recovery and peacebuilding (2011) Anke Hoeffler, Syeda Shahbano Ijaz, Sarah von Billerbeck: http://web.worldbank.org/archive/web-
site01306/web/pdf/wdr%20background%20paper_hoeffler%20et%20al_04dbd.pdf
60 Post-Conflict Economic Reconstruction, Nikolaos Tzifakis: https://pesd.princeton.edu/node/586
61 Post-Conflict Economic Reconstruction, Nikolaos Tzifakis: https://pesd.princeton.edu/node/586
62 Post-war Reconstruction: Concerns, Models and Approaches, Jon Calame: https://core.ac.uk/download/pdf/56704076.pdf
63 Disaster rehabilitation and recovery planning guide of the National Economic and Development Administration in the Philippines (2020) :https://
ndrrmc.gov.ph/attachments/category/12/Disaster_Rehabilitation_and_Recovery_Planning_Guide_NEDA.pdf?deliveryName=FCP_4_DM130266
64 https://council.science/uk/annual-report-2020/hazards/

23
• inclusion of disaster risk management in disaster recovery processes;
• sustainability of new and existing critical infrastructure to ensure its safety, efficiency and effectiveness
during and after disasters, to ensure life-saving and basic services.

The example of Coventry (England) demonstrates how a reconstruction plan that quickly generates a small
number of professionals without public consultation can have the opposite effect. This plan was based on er-
roneous assumptions about the development of the city and the social behavior of its inhabitants. In particular,
the architectural past, which still had psychological value for local communities, was not preserved, and urban
aesthetics was imposed due to fashion rather than pragmatism.65

6. Identification of fund managers, executors of other forms of assistance

The institutional limitations of fund managers in terms of authority, resources, political support and expertise
should be recognized.66
A team of post-war reconstruction researchers who studied this process in Bosnia and Herzegovina,Kosovo,Leba-
non,Palestine,Mozambique,Sierra Leone,Afghanistan and EastTimor noted that a common characteristic was the
imbalance between the rapid influx of aid to a country with weak institutions and the increasing needs of people.67
This study also provides examples of government institutions inheriting corrupt and unaccountable practices
from the war period:
Palestine - when the money laundering techniques that the Palestine Liberation Organization (PLO) learned
during its four decades of struggle were not forgotten when its leadership took control of the Palestinian
Authority;
Bosnia and Herzegovina, where wartime networks controlled public sector appointments, leading to close
networks of patronage and capture of the privatization process.
This study also emphasizes that insufficient information leads to poor coordination. This allows several effec-
tive ministries to receive a disproportionate share of aid. For example, at the beginning of this decade, several
Palestinian ministries with significant ties received the lion’s share of aid, while others were cut off.

7. Determining the amount and provision of funding or other resources for certain ob-
jects
At this stage, the risks are associated, in particular, with the objectivity and timeliness of the allocation of funds
and resources in accordance with the defined goals and priorities.
The efforts to finance reconstruction in Dubrovnik, Croatia illustrate the pitfalls of a non-systematic ap-
proach. The uncoordinated early stage of reconstruction68, the scattered and intermittent flow of donations,
had a number of undesirable results. For example, there was an excessive emphasis on Old Town structures
due to one-sided media coverage. Also, in the future, the reconstruction budget is associated with resources
that are difficult to predict or control.69
Poor information creates insufficient supervision. Thus, no information resource covered all aid projects in
Palestine, the first large-scale assessment of aid was conducted by UNDP 7 years later (in 2000). The report
concluded that most aid projects were urban. Rural areas and refugee camps, where help was most needed,
were neglected.70

65 Post-war Reconstruction: Concerns, Models and Approaches, Jon Calame: https://core.ac.uk/download/pdf/56704076.pdf

66 Post-war Reconstruction: Concerns, Models and Approaches, Jon Calame: https://core.ac.uk/download/pdf/56704076.pd
67 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf

68 The later stages demonstrated the value of local initiative and competence, which increased in the first years after the cessation of hostilities
69 Post-war Reconstruction: Concerns, Models and Approaches, Jon Calame: https://core.ac.uk/download/pdf/56704076.pdf
70 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf

24
8. Procurement of goods, works, services for public or private funds
This stage includes the risks inherent in public procurement in general at different stages:
• formation of technical task, order;
• determination of performers;
• use of funds by the contractor and acceptance of works, services, facilities.
Public finance management practices are ill-suited to disasters under normal conditions. Standard monitoring
processes are at odds with the need for governments to act quickly to assist affected populations and restore
services. However, urgency is not incompatible with proper control and accountability. Governments must
demonstrate that funds are distributed fairly and support those who need it most.71
9. Using the result for its intended purpose
In some cases, it may be important to monitor the targeted use of rehabilitation measures (such as social
infrastructure).

Phases and dissonances of post-war reconstruction.

Also, when considering the issue of corruption risks at different stages for reconstruction, it is important
to take into account the phases and dissonances of post-war reconstruction. The study of post-war recon-
struction (in Bosnia and Herzegovina, Kosovo, Lebanon, Palestine, Mozambique, Sierra Leone, Afghanistan and
East Timor) notes that according to data collected by the World Bank, aid flows are on a rising and falling
curve. There is rapid growth in the coming postwar years, followed by a sharp decline and the possibility of
gradual growth thereafter. The description of these phases is given in the table.72

phase period features dissonance factors

“The Potlach begins with focus on peace and “quick a period of unrealistically high expectations of
Effect73” the onset of victories” communities and donors
peace, the
greatest prog- rapid growth of foreign aid low accountability (tendency to ignore corrup-
ress is mea- inflows tion factors)
sured in weeks
and months the ability of the state and weak formal accountability structures
civil society institutions to
absorb support is usually high corruption risks
inconsistent with its pace
and volume

the amount and nature of

assistance too rarely meet
the needs of recipients
(often exceed)

71 Disaster Resilience and Responsive Public Finance Management: An Evaluation Tool, International Bank for Reconstruction and Development, World
Bank, 2022: https://openknowledge.worldbank.org/handle/10986/37033

72 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf
73 the concept is borrowed from the rites of indigenous tribes in the United States and Canada: «potlatch» — a ritual in which generous gifts of clothing,
food and valuables are given to another tribe or family regardless of the needs of recipients, or even their ability to consume them

25
 phase period features dissonance factors

“opening first 3-4 years first gap occurs: often the opportunity for reform is lost
moment” after a peace-
for major ful settlement the range of development
reforms needs and the absorption
capacity of government
institutions is growing

aid volumes are declining

“Late awak- in 4 - 10 years second gap occurs: expectations turn to disappointment
ening” after the
beginning of period often coincides corruption models are consolidated
reconstruction with a reduction in aid;
high level of perception of corruption
the range and level of
development needs and high demand for accountability (internal critics
the absorption capacity of and donors will make demands for accountabil-
government institutions is ity)
maintained
high risk of conflict

It should be noted that the above team of researchers identified six potential areas of high risk that
should be assessed and addressed at an early stage:
• income from valuable natural resources and drugs, both in Afghanistan and East Timor;
• privatization of state assets, as in Mozambique;
• control of reconstruction assistance programs (including major infrastructure projects) through net-
works of influence, as in Bosnia and Herzegovina;
• systemic corruption in property rights, as in Lebanon;
• state control over public institutions through patronage networks, nepotism or the purchase of key
ministries, as in Afghanistan and Kosovo;
• consequences of a political settlement, such as the Palestinian state’s monopolistic control over basic
commodities and food, such as oil, flour and petrol.

Corruption is rooted in one or more of these six areas, can provide access to significant incomes, affect large
numbers of people, and destabilize the state-building process. The potential benefits of reform interventions
in these areas should be weighed against their potential to destabilize the country.

Because corruption is by definition created to avoid detection, its most pernicious forms will only be detect-
ed if they are proactively sought. The prevention strategy should begin with an analysis of these six areas of
risk. This work can begin with an early post-war needs assessment study.

Although the fight against corruption can destabilize, corruption cannot be ignored. Systemic corruption is
incompatible with the fundamental principles of state formation.

Stages of monitoring, evaluation and communication

The Disaster rehabilitation and recovery planning guide of the National Economic and Development Admin-
istration in the Philippines (2020) notes that:

26
• rehabilitation and restoration program should provide a mechanism for monitoring and evaluating
projects;
• communication strategy may be part of a rehabilitation and restoration program or a separate docu-
ment.
Evaluation of the progress and results of the recovery plan and their coverage
Project monitoring and evaluation should include the organizational structure, monitoring mechanisms, re-
porting, and the monitoring tool to be used.

Monitoring usually includes reporting on the status of implementation of individual projects, programs, ac-
tivities (inputs, results and processes, measures to address delays in implementation and on-site verification).

Disaster rehabilitation and recovery planning guide of the National Economic and Development Administra-
tion in the Philippines (2020) emphasizes the importance of establishing a mechanism and providing monitor-
ing functions at the beginning of the recovery program.

The following main functions of the monitoring unit are given:

• establishment of key performance indicators;
• assistance to the involved agencies regarding the monitoring system and tools;
• consolidation of monitoring reports provided by agencies and local governments;
• creation and regular updating of a database of monitored programs and projects;
• coordination of the involved agencies to identify problems in the project implementation and recom-
mendation on actions to be taken;
• preparation of periodic reports on the status of implementation of programs and projects for submis-
sion to the Council and, if necessary, to the President;
• verification, if necessary, of agency reports by evaluating key projects on the ground.

The Guide also provides recommendations for a monitoring tool. It is noted that it can be developed on the
basis of existing operational tools, provided that they can be easily modified, if necessary. It is considered
more effective to use standard tools and templates for all recovery programs at the national and local lev-
els. This minimizes the need for staff training on new monitoring tools for each disaster.

A combination of online (based) and offline (i.e. MS Excel or MS Access) tracking tools is also recommended
(in case of problems in the online system).

The tool must allow:

• standardized reporting;
• exchange of data with non-governmental organizations, local authorities and other interested parties;
• obtaining information from the necessary budget and management department forms and other nec-
essary information for monitoring fiscal responsibility.

Governments are encouraged to involve civil society organizations in conducting independent third-party
assessments based on the existing rehabilitation and recovery monitoring system. This can promote trans-
parency and accountability.

Results evaluation is recommended to determine the effectiveness of interventions. This is especially true for
large-scale disasters.The results of the evaluation determine what other necessary assistance the government
needs to provide and can also be a basis for improving further recovery projects and activities.
27
The results evaluation can be carried out for the whole recovery program or for individual sectors. For a
comprehensive and balanced assessment of results, an approach that includes consultation with relevant
stakeholders is recommended.
It should be noted that development programs in post-war countries that integrate engagement with local
communities and grassroots social accountability have yielded good results. The monitoring based on citizen
involvement has been used successfully in developing and transition countries such as Brazil, India, Indone-
sia, Mexico and Uganda. Several cases are known in post-war countries. A focus on local accountability and
monitoring from below helps citizens regain confidence in the recovery process and root out localized cor-
ruption.74
Communication strategy

The Disaster rehabilitation and recovery planning guide of the National Economic and Development Admin-
istration in the Philippines (2020) stated that the communication strategy facilitates recovery by providing a
platform for information exchange, feedback and problem solving.

The Philippine experience involves the development at the beginning of the recovery phase of communication
strategies by a leading agency, local governments.

This tool can build trust, promote active participation and provide consensus on programs and projects
among key stakeholders.

It emphasizes the importance of timely support for the flow of information so that stakeholders are informed
and encouraged to participate in solving problems related to reconstruction.

Government agencies and local authorities should designate coordination centres for such communication
activities and establish reporting mechanisms to ensure the smooth flow of disaster and recovery informa-
tion.

The snapshot report will be useful in providing an overview of the pressing issues of rehabilitation and re-
covery and new trends so that government leaders can make informed decisions. It can be distributed to
agencies, local governments so that they have the same guidelines.

It also helps to manage people’s expectations by providing proactive messages to address or clarify recovery
issues (for example, possible delays in the implementation of programs and projects, issues related to the
selection process for beneficiaries, etc.).

Regarding the problem of transparency in the use of funds, this Guide recommends reporting on the status
of project funding, including:

• identified sources of project funding;

• the status of the use of public funds;

• funds planned or actually transferred to the government.

• Good communication contributes to other goals throughout the recovery process, including trans-
parency, accountability and good governance.

Conclusion:

According to the experience of post-war reconstruction described in this section, it should be taken into
account that aid flows follow an upward curve followed by a sharp decline and the possibility of a gradual
increase thereafter.
74 Integrity after the war. Why Reconstruction Assistance Fails to Deliver to Expectations, Fredrik Galtung and Martin Tisné, http://www.gsdrc.org/docs/
open/innovations-in-accountability/ia7.pdf

28
The early post-war years have seen high rates and volumes of aid, which are usually not matched by the ability
of states to utilise support. This is a period of high expectations of communities, donors, low demands for
accountability, and high corruption risks. The first 3-4 years of peace are called the “opening moment” for
major reforms.The range of development needs and the absorptive capacity of governments is growing, while
aid levels are declining. The opportunity for reform is often lost.
The period of 4 to 10 years after the start of reconstruction often coincides with a decrease in assistance
while maintaining development needs. The perpetuation of corrupt patterns with high demands for account-
ability and responsibility is characteristic. There is a high risk of turning expectations into frustrations and
conflicts.
The disaster recovery process usually involves recognizable stages with their own characteristics of corrup-
tion risks and transparency.

Initial collection of information on destruction and assessment of necessary interventions is the basis for
identifying needs and resources for recovery, as well as coordinating donor assistance. It is important that the
damage assessment is based on an internationally recognized methodology for such post-disaster assessment.

Determining the objectives and priorities of the renovation plan requires proper consideration of all areas,
current needs and available resources. Mechanisms for transparency, accountability and stakeholder consul-
tation are important for this.

These mechanisms, as well as planning and coordination are needed at the stage of defining tasks for the
restoration of certain industries and territories. At the same time, a bottom-up approach is recommended
to take into account the aspirations and needs of local communities, the private sector, non-governmental
organizations and to build confidence in the government’s recovery efforts.

The sources of resources for reconstruction should be weighed against their potential to trigger develop-
ment control or uneven development in the country.

It is important to ensure the accountability of international non-governmental organizations - recipients of

funds for reconstruction tasks, their coordination. This avoids inefficient use of funds, duplication of projects,
reduces corruption risks.

When identifying fund managers and implementers, their institutional limitations in terms of authority, re-
sources, expertise and their inherited corrupt, unaccountable practices from the wartime and pre-war peri-
ods should be recognized.

Adherence to the goals, priorities and legally regulated mechanisms of recovery reduces corruption risks
in the stages of determining measures, deadlines for recovery, the amount and timely funding for specific
facilities. Transparency, coordination and a systematic approach, information resources covering all assistance
projects are important.

Standard public finance and procurement management processes should be aligned with the need for gov-
ernments to act quickly during the recovery period. This should include proper control and accountability to
ensure a fair distribution of funds.

Recovery programs should provide a mechanism for monitoring and evaluating projects, as well as commu-
nication strategies.

29
CORRUPTION RISK MANAGEMENT

The Practice Guide on the Use of Public Financial Management Systems75 provides two main mechanisms for
financing international aid:
• Providing assistance in the form of goods and services without allocating funds to the government of
the recipient country.
• Allocation of funds to the government of the recipient country using certain procedures for managing
these funds.
A survey conducted by the authors showed that all donors are willing to use any of these mechanisms, or a
combination of them, if necessary. Both approaches carry corruption risks and require mitigation measures.

Donor-side corruption risk management

Extrabudgetary assistance is chosen in cases of low recipient capacity, to circumvent bureaucratic processes
at the recipient or for other reasons. In the case of assistance, the direction of corruption risk management
mainly depends on donor organizations.
The Recommendations of the Development Cooperation Council on Corruption Risk Management76 set out
10 principles to be applied in risk management on the part of donors.

1. A code of conduct (or equivalent) that specifies which forms of corruption behavior should be avoid-
ed and which should be encouraged. The code should apply to all public persons and be approved by
the top management of the development agency.
2. Ethics and anti-corruption counselling for staff. Appropriate financial and human resources, trust and
a non-threatening environment must be allocated for their implementation.
3. Training and raising awareness of anti-corruption for staff (including local).
4. Quality audit and internal investigations. There should be internal audit, external audit, investigations
(internal or external), systematic work to respond to the results of audits and investigations.
5. Systematic work on risk assessment and management at all levels of decision-making and at all stages
of the project.
6. The measures to prevent and detect corruption should be spelled out in contracts. Among them
- identification of persons who have already been convicted of corruption crimes, conducting due
diligence of contractors.
7. Corruption reporting mechanisms and relevant communication.
8. A sanctions regime that is effective, proportionate and encourages refraining from corruption. The
contracts should include the possibility of termination, suspension and repayment, as well as other
civil and criminal actions if corruption is detected. The sanctions process must be transparent and
impartial.
9. A united front in responding to cases of corruption. Donor organizations should support recipient
governments and encourage other donors to respond collectively to corruption. Corruption response
plans should be developed in advance and should be implemented proportionately and progressively if
the situation worsens.
10. Attention to environmental risks. Some of the risks are beyond the direct control of donors and are
related to the management of corruption risks on the part of beneficiaries. Donors should conduct
in-depth analysis of political economy for better anti-corruption program design, work with represen-
75 https://www.oecd.org/dac/effectiveness/49066168.pdf
76 https://www.oecd.org/corruption/anti-bribery/Recommendation-Development-Cooperation-Corruption.pdf

30
 tatives of recipient countries and representatives of donor countries to better fight corruption. The
recipient countries can be provided with resources and technical assistance to improve corruption risk
management systems.

Transparency of donor activities has many benefits, including for donors themselves. Supporting donors’ rep-
utations depends, among other things, on the recipient country’s population and government being aware of
their initiatives.The availability of project data is important to prevent duplication (and the allocation of donor
funds, which often accompanies such duplication). It is important that all donor organizations adhere to the
principle of Publish what you fund77.
The International Aid Transparency Initiative highlights three aspects of transparency78:

1. Traceability: the ability to follow the money through the entire transaction chain;
2. Totality: display of all available resource flows;
3. Timeliness: the availability of an updated picture of available resources in a rapid humanitarian environ-
ment.
The Initiative has developed an Open Data Dissemination Standard79, which already publishes data from more
than 1,000 organizations. Having data on recovery projects in a single format greatly simplifies the analysis of
available resources.

Fighting corruption in the recipient state

A large part of the post-war states belongs to the so-called fragile states, which are characterized by insuffi-
cient capacity, efficiency and legitimacy of governments, which negatively affects their ability to govern. Cor-
ruption directly affects all these factors. The problem of corruption is often not a priority of the government,
compared to the basic needs of the population and post-war reconstruction. At the same time, corruption
has a negative impact, including on these state functions. For the state to use international aid effectively, it is
important to address the problem of corruption from the beginning.
At the time of writing, it is unknown whether post-war Ukraine will be a fragile state. Thus, the government
is likely to maintain legitimacy in the controlled territories, and the bureaucracy, legislation, law enforcement
and other public administration instruments will continue to operate. However, it is obvious that Ukraine will
be closer to a fragile state than in February 2022, at least in the places most affected by the war.Transparency
International highlights the following approaches to fighting corruption in post-war fragile states80:

• Ensuring legality;
• Strengthening financial management systems;
• Strengthening public administration and government accountability;
• Fight against corruption within donor organizations;
• Use of civil society and mechanisms of social responsibility;
• Privatization and economic development.

A quality and accountable financial management system is particularly important for the effective use of
budget assistance. The World Bank’s Disaster Resilient and Responsive Public Financial Management (DRR—

77 https://www.publishwhatyoufund.org/
78 https://www.alnap.org/system/files/content/resource/files/main/an-introduction-to-the-international-aid-transparency-initiative-iati-for-humanitarian-ac-
tors.pdf
79 https://iatistandard.org/en/
80 https://knowledgehub.transparency.org/assets/uploads/helpdesk/355_Lessons_learned_in_fighting_corruption_in_post-conflict_countries.pdf

31
PFM)81 notes that transparency is particularly important in responding to and recovering from natural
disasters. The government must act quickly, while being able to demonstrate that funds are allocated
fairly. Separately, the importance of division of responsibilities is pointed out: one person or group of people
cannot initiate, approve, execute and verify the implementation of activities.
The evaluation program contains a list of criteria that can be easily transformed into recommendations of the
government to reduce fiduciary risks82:
• The Treasury has timely information on the receipt and use of all financial resources aimed at re-
sponding to natural disasters (insurance payments, loans, grants, financial assistance, etc.);
• The chart of accounts or budget classification identifies the following categories of costs related to
natural disasters:
- specific programs, individual items or sub-accounts for disaster-related expenditure;
- costs of disaster response phases (response, recovery, reconstruction);
- costs by type of danger and/or event;
- costs by groups of beneficiaries;
- externally financed government spending.
• Accounting policies and guidelines ensure the traceability of disaster management accounts for bud-
getary and extrabudgetary units, including:
- timely and unified reporting of all government agencies on the costs associated with natural
disasters;
- requirements for the preservation of supporting documents for a reasonable period;
• Central financial agencies record information on the costs associated with natural disasters in a way
that allows it to be easily aggregated, tracked and disseminated through the country’s information sys-
tems.
• The Internal Audit Service conducts audits of response and recovery measures and their costs. There
are:
- Guidelines for conducting internal audits of response and recovery activities and their costs;
- Adequate scope of audit of response and recovery measures and their costs;
- Requirement to audit response and recovery measures, and their costs, during these mea-
sures;
• The Government shall publish the following information on natural disasters in a timely and transpar-
ent manner:
- The rights of individuals, households and businesses to assistance and ways to receive it;
- Assistance programs for individuals, households and businesses, and ways to participate in
them;
- Planned budget expenditures related to natural disasters;
- Information on disaster programs and planned activities;
- Regular budget execution reports on disaster costs;
- Information on public procurement related to response and recovery, including preliminary
information (lists of qualified/ selected contractors) and procurement results (winners, selection cri-
teria);
81 https://openknowledge.worldbank.org/handle/10986/37033
82 Here and below, only the criteria related to transparency and accountability of the public finance system after a natural disaster are given. The criteria
for simplifying and speeding up procedures and actions to be taken before a natural disaster are omitted.

32
 - Reports summarizing the funded activities and their results;
• Disaster costs and information on relevant programs are disclosed in the form of open data with
adequate protection of personal data;

Much more radical measures were introduced in Liberia in 2005. The GEMAP program provided 23 finan-
cial experts - representatives of donors, who had the right to co-sign key decisions in the field of public
finance83. Such measures have drawn criticism for possible violations of state sovereignty. The program had
other aspects, including the need for broad anti-corruption and fiscal reforms to receive assistance. Such
reforms have been unpopular with the political class, but the government has always had the ability to shift
responsibility to donors. Officials and businessmen also had the opportunity to abandon established corrup-
tion practices, citing the fact that “GEMAP is monitoring.” There is reason to believe that these approaches
have been at least partially successful.

External audits and parliamentary supervision ensure that budgets are transparent and available to parliamen-
tarians and the public. These functions must be maintained despite unusual circumstances. DRR-PFM defines
the following criteria:
• The External Audit Service conducts audits of response and recovery measures and their costs. The
service has:
- Guide on conducting such audits;
- Adequate scope of audits;
- Requirements to conduct audits after completion of activities;
• Parliament reviews and evaluates response and recovery measures and their costs;
• Parliamentary hearings on response and recovery measures are public and/or the reports of these
hearings are made public;
• The government holds public consultations on the allocation of funds and response and recovery
measures;
• The government reports on the use of information obtained during public consultations.

External audit services usually focus on conducting financial audits. Current practice involves other types
of audits: a technical audit examines the amount of work physically performed, and a social audit examines
the social, economic, and environmental results of a recovery program for all stakeholders.84 Monitoring and
inspections conducted by ordinary citizens have the potential to restore confidence in the recovery process
and combat local corruption.85
The latest technology can help make government and donor efforts more transparent and understandable to
the public. During the recovery from Typhoon Yolanda, the Philippine government developed several online
tools:
• A site for online monitoring of the progress of all activities related to recovery from the typhoon;
• A site with information about the amounts of declared support and donations from international
organizations, countries and citizens abroad
• A platform for submitting reconstruction projects and tracking the progress of agreed projects.

83 https://www.scribd.com/document/56382921/Post-War-Reconstruction-in-Liberia-The-Governance-and-Economic-Management-Assistance-Pro-
gram#download
84 https://www.gfdrr.org/sites/default/files/publication/DRF-Guide.pdf
85 http://www.gsdrc.org/docs/open/innovations-in-accountability/ia7.pdf

33
In general, it is good practice to have know-your-budget portals, such as the International Bank-sponsored
portal in Uganda.86 Such measures may be synergistic with the above-mentioned DRR-PFM requirements
for adapting the chart of accounts or budget classification to easily track response and recovery costs. The
Ugandan portal also contains a tool for reporting violations of the law87.

Another component of transparency and accountability of public finances is effective public procurement. In
the post-war reconstruction, one of the typical corruption risks is the use of weakened procurement stan-
dards and the provision of substandard goods and services.88 DRR-PFM stipulates that even expedited pro-
curement procedures must ensure accountability, transparency and good value for money. Legislation may
provide for urgent procurement procedures, but this should be complemented by detailed tools and instruc-
tions for use. As with budget issues, DRR-PFM contains a list of criteria:
• The legislation contains standard procedures for accelerated procurement. The circumstances under
which they may be applied and who may apply them are described:
- There are standard procedures, protocols, guidelines that describe how authorities can use
procurement to respond to and recover from disasters;
- There are thresholds for the cost of procurement to respond to and recover from natural
disasters;
• The government has released standard procurement documents for the most frequently procured
goods, services and works;
• The bodies responsible for the preparation and amendments to the standard procurement docu-
ments have been identified.
• The use of accelerated procurement is accompanied by a justification of the need for them;
• The response and recovery contracts meet the following requirements:
- Describe the conditions of implementation;
- Define managerial functionality and responsibilities;
- Establish protocols for timely access to information on each of the phases of procurement;
- Define the functions and procedures for supervising the implementation of the contract;
• The following contract management practices are used:
- Supervision of timely execution of contracts;
- Inspections, quality control, supervision of works and final acceptance of products;
- Examination of invoices and timely processing of payments;
• Summary information on procurement and contract transactions is provided in the reports.
After the catastrophic explosions in Beirut, the World Bank, EU and UN experts prepared: “Rapid assessment
of the damage and needs of Beirut”89. One of the recommendations was to speed up the adoption of progres-
sive procurement legislation and implement a public procurement strategy. Separate bodies for policy-making,
oversight and appeals should be established, e-governance principles introduced, etc. These measures should
be accompanied by the creation of new or strengthening of existing anti-corruption bodies, strengthening of
transparency policies, implementation of legislation on access to information, accession to the Open Gov-
ernment Partnership (OGP)90.

86 https://budget.finance.go.ug/about
87 https://www.worldbank.org/en/news/factsheet/2020/02/19/anticorruption-fact-sheet
88 https://baselgovernance.org/sites/default/files/2019-01/Corruption in natural disaster situations.pdf
89 https://reliefweb.int/sites/reliefweb.int/files/resources/BeirutRapidDamageandNeedsAssessmentAugust2020EN.pdf
90 https://www.opengovpartnership.org/

34
Conclusions
Any aid program has corruption risks that need to be managed. Risk management in extra-budgetary assis-
tance programs (direct humanitarian aid, investment projects, technical assistance, etc.) is generally dependent
on donors.The key factors are the inclusion of anti-corruption measures in the program design, transparency,
regular audits, interaction with other donor organizations. Fiduciary risks arise in budget assistance programs,
the management of which is the responsibility of the recipient government. In the post-war reconstruction
situation, it is important to adapt the financial management system in such a way as to ensure the traceability
of all funds allocated for reconstruction, the possibility of control by auditors and parliament, the availability
of information to citizens. Ideally, there will be a need for quick decisions on allocation and procurement, so
it is important to develop clear procedures without harming transparency and accountability.

35