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Corruption in the Mining Sector: Preliminary Overview 395
some element of discretion still remains (namely, as to whether the
licensee has complied with the requirements), that discretion has been
largely minimized by the clarity of the regulations.
• The risk of registration date manipulation (caused by MOM needing to
obtain clearance from the regional or city licensing authority that a
license area is available) is likely to be minimized by the introduction
of the new computer database that will show all federal, regional, and
city licenses. The federal mining minister also receives a status report of
all federal license applications every two weeks.
• Separation in functions is achieved at the federal level (a) because officials
from different MOM departments assess which mining, environmental,
and social conditions to apply to the issuing of a license, and
(b) because of the separation in function between the department issuing
the license and the department administering the license. This separation
of functions reduces the chance of corruption in license issuing
because if corruption results, for example, in unduly weak license conditions,
the license administration department may spot this deficiency
and query it.
• Access to information at the federal level is good because the MOM
computer shows the current status of all federal license applications,
including the status of federal licenses (for example, type of license,
identity of license holder, nationality of license holder, location of
license, type of mineral) and the location of federal licenses on a map.
This database helps to identify trends and comparisons that may reveal
corruption (for example, if one company receives an unusually high
number of licenses).
• Officials at MOM and at the Oromia Regional and Addis Ababa City
licensing authorities appeared to be knowledgeable about their areas as
well as enthusiastic, intelligent, and determined to ensure that the system
worked well. Some mining companies spoke highly of the capability
of some licensing officials.
• The risk of conflict of interest at the federal level has been reduced by
the Ethiopian Environmental Protection Authority’s (EPA) requirement
that the mining company prepare the environmental impact
assessment independently of government. No official is permitted to
help prepare the assessment. The mining company is required to sign