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Transparency Initiative (EITI)

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89<br />

where transparency can lead to reform. However, the<br />

study could not identify robust methodology in the Validation<br />

process as established in 2016 that would consistently<br />

detect whether there is freedom to debate the<br />

outputs of the <strong>EITI</strong>. In the validation reports of the past,<br />

there has been very little consideration of this, despite<br />

it being a part of the 2011 Rules. The “custodians” of the<br />

Standard, the <strong>EITI</strong> Board and International Secretariat,<br />

can only guarantee the production and assurance<br />

of the Requirements under the <strong>EITI</strong> Standard, which is<br />

done through the Validation process. Unless the Board<br />

integrates items into the standardized <strong>EITI</strong> methodology<br />

and/or the Secretariat includes those in the guidance<br />

notes which interpret the Requirements, countries<br />

can dodge the debate and political consequences, and in<br />

doing so they are able to delink increased transparency<br />

from increased accountability.<br />

19. No overarching ‘transparency and accountability metrics’:<br />

Given the broad range of objectives and institutional<br />

solutions observed, this study found it feasible to<br />

produce a generic results model, but not feasible to develop<br />

a single overarching indicator for <strong>EITI</strong>-induced<br />

systemic sector development or ‘transparency and accountability<br />

metrics’ that cover the diverse set of 50<br />

plus country cases. The <strong>EITI</strong> is implemented by countries<br />

and indicators measuring impact need to fit to the<br />

individual country case of systemic strengthening of<br />

good governance. The theory of change and the generic<br />

<strong>EITI</strong> results model of the study is designed to cover this<br />

demand-driven and flexible approach.<br />

EFFICIENCY<br />

20. Research into its own impact neglected: None of the officially<br />

mandated evaluations and reviews has served<br />

the purpose of producing longitudinal baseline data.<br />

They could have equally been commissioned along<br />

the given questions of interest (e.g. Scanteam 2011 evaluation<br />

informing the strategy reform that led to the<br />

Standard 2013). In that respect, the <strong>EITI</strong> has not used<br />

its resources meaningfully to conduct research into its<br />

own impact.<br />

21. Accountability of remunerations: Country case studies<br />

indicate that remunerations for <strong>EITI</strong> activities and<br />

per diems in lesser developed countries can be out of<br />

balance with poverty or income levels in those countries.<br />

They may, however, be in balance with the level<br />

of internationally funded activities in the respective<br />

country, unrelated to <strong>EITI</strong>-specific conditions. The <strong>EITI</strong><br />

has no rules against this but encourages accountability<br />

through the Board (Rich/Moberg 2015: 110). The review<br />

of literature and documents did not produce a full picture<br />

of modes of delivery, allocation of budgets and aspects<br />

of cost-efficiency – and neither did the interviews.<br />

This impedes a fair and sound assessment of the efficiency<br />

of the <strong>EITI</strong>.<br />

SUSTAINABILITY<br />

22. Consensus to make transparency meaningful for the<br />

target groups: The <strong>EITI</strong> is unified in the approach to<br />

make transparency meaningful for the target groups<br />

(e.g. Progress Report 2016 – From Reports to Results). It<br />

has been widely ascertained by stakeholders that more<br />

of the same (publishing reports that remain largely unread<br />

by the target audience in some countries) does not<br />

lead to better results and can at a certain point be an<br />

impediment to impact and sustainability.<br />

23. Decisions by consensus, not sufficiently based on evidence:<br />

The question of whether the 2013 Standard is<br />

sustainable is a critical one. By heavily engaging the EI-<br />

TI in routine operations at country level implementation,<br />

it became less of an ‘initiative’ and more of an ‘organization’.<br />

An extensive strategy review was conducted<br />

by the <strong>EITI</strong> prior to the Standard and a governance review<br />

thereafter, but there was no ex-ante evaluation to<br />

provide a systematic basis of evidence before the farreaching<br />

decision to introduce the Standard was taken.<br />

Ex post, an external and independent assessment<br />

came to the conclusion in early 2015 that not a single<br />

one of the <strong>EITI</strong> countries had met all the governance<br />

Requirements of the Standard (MSI Integrity 2015). Given<br />

that not all countries have reported under the Standard,<br />

let alone been validated against it, the bulk of firsttime<br />

Validations will not be completed until the end of<br />

2017 and will likely show results of rather weak national<br />

M&E systems. Furthermore, officially mandated evaluations<br />

of the <strong>Initiative</strong> have not been applied, which<br />

could be of use to guide decisions.<br />

24. The <strong>Initiative</strong> holds a key to change the governance dimension:<br />

Regarding the dimensions of economic, social<br />

and environmental sustainability, the <strong>EITI</strong> has the

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