Integrity
Integrity
Integrity
August 2015
Project Team
Acknowledgments
The project co-leads, the CEO Water Mandate Secretariat and the Water Integrity
Network, as well as the rest of the project team would like to thank the German service
provider for sustainable development, Deutsche Gesellschaft für Internationale
Zusammenarbeit (GIZ) commissioned by the Federal Ministry for Economic
Cooperation and Development (BMZ) and the United Kingdom’s Department for
International Development (DfID), whose funding support enabled the development
of this guide. In particular, we would like to appreciate the continued support and
insights we received from the team of the GIZ International Water Stewardship
Programme (IWaSP). We would also like to recognize and thank the members of
the Integrity in Water Stewardship Initiatives Advisory Board and the CEO Water
Mandate’s Collective Action Working Group for their ongoing support and feedback
throughout the development of the guide. (The members of both groups are listed
in Part Three: Informational Appendices — Appendix C: Methodological Approach.)
Disclaimer
All of the views expressed in this publication are those of the project team and do
not necessarily reflect those of the project sponsors or the members of the Advisory
Board or Collective Action Working Group.
August 2015
August 2015
Foreword
Sustainable water management contributes towards human and economic development as
well as protecting valuable environmental assets and services. However, the political support
and the investment to deliver effective Water governance and the infrastructure needed to
manage water equitably and sustainably are often lacking in many countries. This creates
“water risks” for a wide range of stakeholders. Today nearly 800 million people still do not
have access to safe drinking water and roughly one-third of the world’s population lives in
water-stressed areas. As the world’s population grows, demand for water increases and climate
change threatens water quality and availability it is essential that greater effort is placed on
ensuring sustainable water management in order to promote healthy and more prosperous
societies.
In recent years an interesting response to the failure to invest in sustainable water management
has emerged from a, perhaps unlikely, quarter. Investors and companies are increasingly
engaged in debates and programmes to improve water management. This is exemplified by
the World Economic Forum’s 2015 Global Risks report which identified water crises as the
number one risk in terms of impact. There is a growing body of local evidence demonstrating
the threat of water risks for companies and economies. The Thai floods of 2011 were deemed
the fourth most costly natural disaster ever, with costs of over $45bn causing the Thai economy
to shrink by 9%, and significant impacts felt by multinational companies and other countries
across the world. There are thus clear threats to the private sector of failures to address water
risks – not just in their investments in factories or supply chains but in wider catchments.
Water stewardship has emerged as a broad framework bringing together a diverse range of
companies, communities, governments, NGOs, civil society and donors to tackle shared water
risks in order to deliver a wide range of social, economic and environmental outcomes. But
can increased corporate engagement in water risk management meaningfully contribute
to wider efforts to eradicate poverty, promote sustainable economic development, increase
resilience to climate change and improve environmental protection? This question is at the
heart of efforts to engage the private sector in efforts to deliver sustainable and equitable
water management.
Water stewardship initiatives are relatively new. As such the evidence regarding their efficacy
is still limited and much work has been through a process of trial and error. And many still
question whether corporate engagement is anathema to sustainable and equitable water
management arguing, for instance that, it can lead to policy and resource capture or provide
companies with increased access to decision-makers and information. With WSIs at a nascent
stage in their development this Guide on Managing Integrity therefore provides a timely and
invaluable stock take, assessing progress and drawing out key lessons learnt in delivering WSIs.
Adhering to the Principles set out in this Guide and using the associated tools will help Water
stewardship initiatives proceed with high levels of accountability and transparency
and ensure that all stakeholders – including the poorest and most vulnerable – truly
benefit.
The Sustainable Development Goals set out a universal framework to deliver water
management as a driver of poverty eradication, increased prosperity and enhanced
biodiversity. The SDG framework identifies the private sector as a key means of
implementation. I would argue that Water stewardship has a potentially important
contribution to make towards delivery of the SDGs.
A key focus of DFID support is to ensure effective lesson learning – highlighting the
successes, of course, but also honestly reporting the challenges and difficulties in
delivering Water stewardship so that others may learn from these lessons. Only this
way will replication and scale up be possible.
Jean-Paul Penrose
Senior Water Resources Adviser
Department For International Development
This piece of work was commissioned by the International Water Stewardship
Programme (IWaSP). IWaSP is an innovative donor funded programme that
improves water security for communities and businesses in watersheds around
the world by supporting good corporate water stewardship and multi-stakeholder
collective action. IWaSP is implemented by the Deutsche Gesellschaft für
Internationale Zusammenarbeit (GIZ), on behalf of the German Federal Ministry
for Economic Cooperation and Development (BMZ) and the UK Department for
International Development (DFID).
IWaSP enables public sector, private sector and civil society actors to reach
consensus on water risks and solutions, and partner to implement joint action
plans, improving ecosystem protection, water supply access, infrastructure
investment and water governance.
IWaSP believes that the scale and urgency of the water crises facing many of the
world’s watersheds and cities present a pertinent need to collectively address
shared threats to water security. However, it also recognises that public sector-
private sector-civil society collective action approaches present significant new
challenges, and that there are many lessons still to be learnt.
For example, how to build trust amongst stakeholders that are not used to
cooperating with each other? Or how to manage the often significant power
imbalances between multi-national companies, public authorities and local civil
society organisations, to ensure fair planning and decision making processes, and
outcomes that benefit all? Or how to meet what is often the private sector’s need
for quick results without bypassing ‘slow’ but important public authorities and
governance processes? These and similar such challenges are almost certainly faced
by all organisations committed to taking an equitable and sustainable approach
to implementing water stewardship initiatives. However, independent, pragmatic
and well thought through guidance on how to best collaborate in an inclusive,
transparent and accountable manner in what are often complex initiatives has
been lacking until now. To help fill this knowledge gap, IWaSP commissioned
the CEO Water Mandate and Water Integrity Network, in partnership with
other thought leaders, to develop this practical, solutions-orientated guide for
practitioners who are managing water stewardship initiatives.
Contents
Part One: The WSI Integrity Management Guide..............................................11
I. About This Guidance and Background ..................................................................................................................11
II. Understanding Integrity Risks Facing WSIs ................................................................................................... 16
III. Operating Principles for Managing the Integrity of WSIs...........................................................................21
IV. Applying the WSI Integrity Principles in Practice.......................................................................................... 27
10 August 2015
The WSI Integrity
Management Guide
I. About This Guidance and Background
Increasingly, there is recognition that sustainable water management Sustainable water management
(SWM) requires action by not just government but also business and civil is defined as the management of
society. It is derived from the underlying concept of integrated water water resources that holistically
addresses equity, economy, and the
resources management that ensures efficient, equitable, and sustainable
environment in a way that maintains
development of the world’s limited water resources. Companies that the supply and quality of water for a
rely on water for their core business (e.g., in the manufacturing of their variety of needs over the long term
goods or indirectly in the production of their inputs) recognize that they and ensures meaningful participation
face water-related risks. Increasing water scarcity and pollution of water by all affected stakeholders.
sources combined with inadequate Water governance systems have led
to a clear business case for action, based on the proposition that more
effective water management can help address and mitigate such risks. In this guide, water stewardship
Corporate Water stewardship is founded on the notion that businesses initiatives (WSIs) are defined as
coordinated engagements among
can act in a positive manner to manage their risks and simultaneously interested parties (most often
meet local stakeholder expectations by mitigating adverse impacts on including businesses) to address
communities and ecosystems, thereby helping to protect a vital shared specific shared water challenges.
resource. WSIs typically involve structured
collective action and joint decision
Generally defined as the use of water in a way that is socially equita- making and implementation to ensure
ble, environmentally sustainable, and economically beneficial, Water use of water that is socially equitable,
environmentally sustainable, and
stewardship is achieved through a stakeholder-inclusive process that
economically beneficial.
involves site- and basin-based actions. Water stewardship involves orga-
nizations taking shared responsibility to pursue meaningful individual
and collecttive actions that benefit people and nature.1
1 Adapted from Alliance for Water stewardship (AWS), “What Is Water stewardship?” (2010), http://www.
allianceforwaterstewardship.org/become-a-water-steward.html#what-is-water-stewardship.
The initiatives formed between multiple stakeholders in a WSI constitute a form of “collective action”
toward a shared water management goal. Collective action can be understood through a four-level taxonomy
that is described in Table 1. These four levels of collective action differ in terms of the resource commitments
required and the formality of decision-making and governance structures. The WSIs that are the focus of this
guide reside within the collaborative and integrative levels of engagement. These types of initiatives typically
have a degree of formality and focus on working toward common objectives. Integrative partnerships typically
require more substantial (and often pooled) resources, and put substantial effort into establishing concrete
alignment of interests and objectives among all parties, thereby increasing coordination and establishing
clear roles and responsibilities for all parties.
Level Description
Focuses on coordinating the sharing of information to foster expanded knowledge and increased
Informative
transparency, familiarity, and trust among interested parties.
Focuses on convening specific interested parties to exchange ideas and expertise, and to create a
Consultative shared understanding of needs, interests, and challenges to enable informed, independent decision
making by all parties.
Seeks to move interested parties closer together and reflects a belief that finding common ground,
Collaborative establishing common objectives, and sharing implementation responsibilities hold the potential to
increase both individual and collective effectiveness.
Emerges when an alignment of interests, resources, decision making, and coordinated actions is
Integrative desired or needed to meet water-related challenges or opportunities. Interested parties are typically
formally convened or have a formal joint structure.
Source: CEO Water Mandate, Guide to Water-Related Collective Action (September 2013),
http://ceowatermandate.org/wp-content/uploads/2013/09/guide-to-water-related-ca-web-091213.pdf.
Worth noting is that collective actions (whether WSIs or less structured forms) can have different primary
objectives. Generally speaking, they can (1) deliver projects and programs, (2) support the creation of new
accountability mechanisms (certification schemes, regulation and policy frameworks, complaints redress
mechanisms, etc.), (3) create a resource transfer mechanism (that channels funding, expertise, and in-kind
support or products, spare parts, etc., to worthy or needy areas), or (4) provide a dialogue, learning, and
innovation platform for stakeholders. Each of these functions brings a different spirit of engagement,
calls for different decision-making mechanisms, and may involve a different configuration of participants.
Needless to say, ultimately WSIs need to be tailored to fit the context in which they are operating and the
goals they are trying to achieve.
12 August 2015
Case for Ensuring Integrity in WSIs
A key aspiration of WSIs is to address shared water challenges to the benefit of all participants and affected
stakeholders. WSIs that go awry, in contrast, may end up generating benefits for only a few WSI participants
to the detriment of other particular interests or society as a whole. Adhering to integrity principles within
WSIs helps ensure that efforts lead to shared benefits, particularly when such efforts involve participants
with varied and at times conflicting interests. Focusing on integrity in WSIs brings advantages, including:
2. Generating greater credibility and reducing reputational risks for WSI participants
4. Supporting WSI participants’ staff or representatives through clear articulation of the rules for
engagement.
In addition, WSIs have the potential to improve Water governance, either by directly tackling local
governance challenges or through the WSI’s indirect benefits. Water governance refers to “formal and
informal processes that allow for the determination and negotiation of objectives, setting of standards, and
resolution of disputes among disparate voices in order to address challenges and meet objectives at local,
sub-national, and national levels.” It is a complex process that considers multi-level participation from not
only government institutions but also the private sector, civil society, and citizens. Good Water governance
means that the actions (and inactions) of all parties are transparent and accountable so that undue influence
is minimized, the views of minorities and the most vulnerable are heard in decision making, and the needs
of the present and the future are taken into account.
Ensuring the integrity of WSIs is therefore part and parcel of efforts to improve Water governance, and
WSIs with high levels of integrity can make an important contribution to improving overall water sector
performance.
Understanding and properly managing integrity risks is essential to ensure the long-term effectiveness and
impact of WSIs in addressing shared water challenges.
1. Clear objectives and demonstrable outcomes that advance sustainable water management
3. Inclusive, transparent, and responsive processes and governance that lead to informed and
balanced decision making
NOTE: Throughout this guide, the color coding above — the outcomes (blue), the individual
participants of WSIs (purple), and the processes and governance of the initiative (green) —
is used to reflect these three dimensions of integrity relating to WSIs.
Participants: Individuals or
organizations that are actively Overview of Structure—
participating in the design and
implementation of a WSI. Participants
How the Guide Should Be Used
can come from any sector but must
have committed resources and/or These guidelines are organized into two main parts: the first part
time to the initiative.
introduces a framework for WSI integrity management, and the second
part is a collection of practical tools that can be used by practitioners as
they embark upon key activities relating to their Water stewardship
collective action.
14 August 2015
FIGURE 1:
Figure 1:Components
ComponentsofofWSI
WSIIntegrity
IntegrityManagement
ManagementFramework
Framework
Supporting Tools
Help Inplement Activities
Section II introduces the various risks that WSIs typically face in practice.
Section III describes seven principles for addressing these common WSI integrity issues, and introduces
guiding questions that can be used to bring these operating principles to life.
Section IV provides detailed guidance on how the WSI integrity principles can be applied in practice
through key activities mapped across the life-cycle phases of a WSI.
Part Two of the guide contains a suite of 12 tools that support successful implementation of various activities
described in Section IV. It is left to participants in a given WSI to decide which of the tools in the toolbox to
use (or adapt) given the scope, function, and context of their work and the potential gaps faced in planning,
participation, or setting objectives.
Part Three provides a series of informational appendixes to help understand key sections of the guidance,
including more detailed integrity risk descriptions and a one-page synopsis of the primary activities
practitioners should undertake when pursuing a Water stewardship collective action.
A glossary of key terms is also provided at the end of the guide. Terms defined in the glossary are
shown when first used in the guide indicated by bold text and a dotted underline and in the PDF
version of this guide they are bookmarked to where the term can be found in the glossary.
This guide should be considered as an evolving body of work that will be amended and updated over time
as WSI practice matures. This guide has also been developed into an online platform, which can be found at
http://www.ceowatermandate.org/integrity.
Fieldwork undertaken for this project has identified the range of integrity risks facing WSIs through analysis
of 18 historical, ongoing, and emerging WSIs and 50 interviews with diverse stakeholders involved in them.2
These case study WSIs covered a range of multi-stakeholder and corporate engagement activities on water,
including local project implementation, establishing novel financing mechanisms to improve water supply
and/or quality, convening for policy dialogue or planning, and supply chain engagement.3 Findings were
presented, discussed, refined, and validated through a series of six international meetings.
The integrity risks that emerged have been grouped within 15 WSI integrity risk areas, which are summarized
and mapped in Figure 2.4 As discussed in more detail below, the relevance of these risks varies depending
on the nature, objectives, maturity, and context of a particular WSI. Correlating with the definition of WSI
integrity presented above, risk areas can be attributed to the initiative’s outcomes (blue), the individual
participants of WSIs (purple), and the processes and governance of the initiative (green). Integrity risks areas
with the potential to have more severely negative social, economic, environmental, or institutional impacts
were assigned a higher hazard ranking than those whose negative impacts would most likely affect individual
Figure 2:
WSI participants or the internal dynamics and efficiency of a WSI. The integrity risk areas found in the top
Ranking of WSI Integrity Risk Factors Based on Level of Hazard and Likelihood
right quadrant of Figure 2 are those of most concern across the case study WSIs analyzed during the fieldwork.
Figure 2: Ranking of WSI Integrity Risk Factors Based on Severity and Likelihood of Hazard
Partner representation
FREQUENCY / LIKELIHOOD OF HAZARD
Partner intent
Inadequate M&E
Partner continuity
PEOPLE
PROCESS
OUTCOME
Low
2 The integrity risks were identified during fieldwork undertaken in Tanzania, South Africa, and Peru, and during consultation meet-
ings in Lima, London, Lusaka, New Delhi, Paris, Pretoria, and Stockholm.
3 Guidance for practitioners on how to undertake an integrity risk assessment for a specific WSI can be found in Tool 1a: WSI Integrity
Risk Assessment.
4 A detailed explanation of these integrity risk areas, as well as an illustrative case example, is included in Part Three Informational
Appendixes — Appendix A: WSI Integrity Risk Descriptions.
16 August 2015
Integrity Risk Areas Related to the Outcomes of a WSI
The extent to which WSIs enhance sustainable water management reflects the degree to which the
collective action has a “stewardship orientation” or whether it is focused primarily on advancing a business
interest. From an integrity management perspective, it is important to ensure that the objective(s) or intent
of a WSI focuses on advancing SWM rather than pursuing vested interests at the cost of public interest and
resources. In this context, a number of integrity risks are related to capture (of public finances, regulatory
action, policy making, and access to water). Additional integrity risks can arise unintentionally via perverse
outcomes where the WSI creates negative impacts for the environment, people, or institutions. Lastly if
the contribution of a WSI to SWM is not properly measured, is very limited in scope and depth, is not
sustainable, or comes at a high cost, then integrity is also at risk alongside the acceptance and perceived
credibility of the WSI by affected stakeholders.
integrity
examples
risk area
integrity
examples
risk area
▨▨ A business participant in a WSI has an appalling record of human rights abuses and
aggressive tax avoidance, and has recently been fined for causing pollution of a high-profile
river.
track record
▨▨ An NGO participant has been prosecuted for corrupt practice in the past.
▨▨ Communities refuse to work with a WSI because a corporate participant is perceived as a
“bad apple.”
▨▨ Key stakeholders affected by or influential to the WSI and its objectives are not in the
room. The main users and polluters of water, the communities affected by degradation and
depletion, and the government bodies responsible for management have not been engaged
representation successfully.
▨▨ Local government, NGO, or business umbrella organizations are involved in the WSI, but they
do not genuinely represent or communicate with the stakeholders they claim to speak for.
▨▨ Businesses do not commit to or seriously engage with the WSI, or do so only for public
intent and relations purposes, or to position themselves for lucrative contracts.
incentives
▨▨ Local government staff only turn up to WSI meetings upon payment of a sitting allowance.
▨▨ The WSI initiator or lead practitioner does not have sufficient experience to design and
deliver the initiative.
▨▨ Civil society organizations are not involved or unable to deliver key roles because they have
capability
no core funds.
▨▨ Government participants are unable to deliver planned work because they are under-
resourced.
▨▨ Inappropriate and dishonest claims are made by one participant about how much they have
achieved through the WSI, without recognizing the efforts of others.
conduct
▨▨ Partner staff do not respond to communications or attend meetings, or have acted
maliciously toward potential partners.
▨▨ The WSI initiator and most active participant has moved on to a new job, leaving no
continuous successor, institutional memory, or commitment to the initiative.
engagement
▨▨ Participants in a WSI modify their objectives or budget commitments.
18 August 2015
Integrity Risk Areas Related to WSI Governance and Processes
Integrity risks related to the governance and management processes of a WSI can be introduced during planning
and design, stakeholder engagement, decision making and communication, financial management, and
monitoring and evaluation. Getting these processes right is critical to ensuring that the WSI delivers on its
objectives and serves the public interest. In the absence of robust, well-designed, and transparent processes
for planning, decision making, stakeholder participation, whistle-blowing, financial management, and
monitoring, WSIs are vulnerable to corrupt behaviors, capture, and manipulation toward vested interests.
Well-designed processes also help with independent oversight, accountability, and legitimacy of the WSI.
integrity
examples
risk area
▨▨ A WSI pays local government staff to clear waste from a river, but it emerges that the
same local government illegally dumps waste into the same river.
planning and ▨▨ A WSI invests in non-viable technologies, infrastructure without operations and
design management planning, or environmentally damaging infrastructure.
▨▨ A WSI generates a payment scheme for watershed services, but this fails due to
competition with existing statutory water use payment schemes, and lack of demand.
managing
responsibilities, ▨▨ WSI meetings are conducted in a language that few participants understand well.
decision making, ▨▨ WSI meetings are poorly managed, not documented, and decisions are not implemented.
and communication
▨▨ A WSI has unclear objectives and cannot demonstrate what it has achieved. Tracking
monitoring,
achievements, implementing corrective management, and ensuring value for money are
evaluation, and
impossible due to the lack of monitoring and evaluation (M&E) framework. M&E data or
learning
results are not shared, hence the motives of partners and role of WSI are questioned.
The nature and extent of integrity risks are largely determined by the contextual environment within which a
particular WSI operates. As Figure 3 illustrates, the three dimensions of WSI integrity (outcomes, participants,
and processes) must be understood in the context of larger political, economic, and environmental conditions.
WSIs need to be sufficiently and properly embedded in the public policy and political realities of a given
country or basin. The relevance of existing policies and legislation, regulations and their enforcement (or lack
thereof), and other basin factors all influence what WSIs can and cannot do, and may inflate certain integrity
Environmental or River Basin Context: Factors include the availability and quality of water; climate
variability and impacts of droughts and floods; important values, uses, and functions of water and water-
related ecosystems; current and future water demand and conflict in the WSI basin. These factors need to be
well understood and considered to identify priorities for the WSI and to inform potential trade-offs among
economic, social, and environmental interests.
Policy, Institutional, and Regulatory Context: The maturity, “personality,” and performance of relevant
river basin and other government institutions will be a key determinant of integrity risks within a WSI. A
particular challenge exists where public policy, law, or the intent of public authorities is not yet aligned
with SWM or with the best interests of local stakeholders and environment. Elements beyond the control
or influence of the water sector, such as land or economic policy, may also have a bearing on WSIs.
Political Context: The political attitudes of local stakeholders and participants toward the problem being
addressed by the WSI, as well as conceptions of multi-stakeholder partnerships, may influence the integrity
of the WSI. External events such as elections or financial crises may shape behaviors and responses to WSI
opportunities.
Socio-Economic and Cultural Context: Socio-economic development factors — such as social cohesion,
demographic shifts, poverty and livelihood considerations, gender, and cultural attitudes toward issues such
as contracts, agreements, access to information, and the rule of law — will have a bearing on the integrity
issues facing a WSI.
Market Context: The interaction and relative power of socio-economic groups and actors affects their overall
bargaining ability and the impact that collusion and capture can have on the distribution of private gains
among WSI stakeholders. How the market functions in particular contexts (the existence of monopolies,
how licenses are issued, etc.) may also shape the incentives and engagement of WSI participants.
CONTEXT
WSI OUTCOME
(i.e. contribution to
WSI PROCESS Sustainable Water Management)
WSI Participant
WSI Participant
Economic
Sustainability
Institutional
Sustainability
Affected Stakeholders
20 August 2015
III. Operating Principles for Managing
the Integrity of WSIs
The integrity risks identified above can be addressed and mitigated by Guiding Questions
adhering to a number of key operating principles. Seven such principles
are introduced here to provide aspirational direction for managing 1. Are public policy priorities in
integrity in WSIs. The operating principles are ordered to correlate with the basin area well defined with
tackling those integrity risks identified as most hazardous as well as regard to water? Are water
most likely. Each is accompanied by a series of Guiding Questions to help policies consistent with other
WSI practitioners understand how to operationalize the principles by public policy priorities?
assessing how well the WSI is addressing certain issues and then helping 2. Are government roles clearly
the practitioners identify key activities to undertake (further explained defined in relation to achieving
in Section IV). water-related public policy
objectives?
Principle 1: Seek to align with, support, and strengthen public policy
3. Do public institutions have
that advances sustainable water management; be careful not to the capacity and resources
undermine public institutions or water governance. to deliver on these stated
objectives (e.g., to enforce the
First and foremost, the WSI should ensure that its scope and objectives regulatory framework)?
support and strengthen public policy relating to SWM. In some
4. Have public sector stakeholders’
instances public policy, laws, and regulations may be weak, ambiguous,
mandates been respected, and
inconsistent, or may not be geared toward delivering SWM. In such cases have those stakeholders been
reforms and review, rather than alignment, may be the priority for a actively involved in setting the
WSI. Where this is the case, it will be important for the WSI to develop a objectives and activities of the
constructive relationship with the government and its agencies, and to WSI?
engage an appropriate range of stakeholders in a sector reform dialogue 5. Are the WSI’s objectives and
in the design, scoping, and implementation of the WSI. activities aligned with public
policy goals and objectives, and
However, in many instances government policy and legal provision are do they structurally support
well aligned with the goal of SWM, and implementation is lacking. In the development of the public
addressing this scenario, a WSI should respect the unique roles that sector’s ability to manage
government institutions play in serving the public interests and water resources? Have public
interest benefits been explicitly
ensure that the initiative’s activities complement rather than usurp
outlined?
or undermine ongoing public policy or Water governance processes.
This can be supported by a well-designed and conducted analysis to 6. Have risks of capturing
understand the local context and political economy, to clarify the root organizational or public
resources, regulatory action,
causes of the problem, and to devise a suitable role and design for the WSI
policy processes, and water
alongside ongoing initiatives. Efforts should also be made to understand access been identified? Have
the resource limitations of public and civil society sectors, in order to such risks been assessed?
guard against potential capture of those sector’s limited resources. How effectively are they being
addressed?
Effectively aligning the WSI with public policy objectives that seek to
advance SWM and understanding the unique role of public institutions
helps to guard against potential policy, regulatory, and resource capture.
Doing so ensures that the WSI is not perceived to be dictating policy
direction, redirecting scarce public funds to serve private interests,
or undermining ongoing public sector–led efforts to achieve SWM
objectives.
22 August 2015
Principle 3: Be clear and transparent about the roles and Guiding Questions
responsibilities of WSI participants, and ensure that their capabilities
are adequate (or are sufficiently developed) to fulfill them. 1. Have WSI participants’ track
records, incentives, and intentions
WSI participants should be able to fulfill their roles and responsibilities, been sufficiently analyzed?
and the WSI needs to develop internal mechanisms to hold participants
accountable against these defined roles and responsibilities. This 2. Have the capabilities and
constraints of each participant
requires a clear understanding of the needs, motivations, and intent of
been properly assessed, and a
WSI participants, and the assignment of clear, suitable roles for each needs assessment conducted?
member. Where skills, experience, or capacity are lacking, the WSI may How will the WSI deal with
carry higher initial integrity risks, but might proceed if the WSI is able to capacity deficits?
provide training, support, or resources to address identified needs.
3. Have roles and responsibilities
for all activities and coordination
Understanding participants’ intentions and any constraints they face,
tasks been appropriately shared?
and establishing clear roles and responsibilities can help to avoid
potential conflicts of interest (where intentions may not be aligned 4. What measures ensure effective
with the goals of the initiative) and integrity risks associated with oversight?
participant capabilities. WSIs that fail to undertake an analysis of the
intentions of their potential participants or to develop structures that
balance the interests among participants and external stakeholders
are at risk of pursuing activities that privilege individual participants
and enable private gain over the public interest. A lack of clear roles
and responsibilities and oversight of these brings risks of corruption and
manipulation by individual WSI participants alongside the integrity
risks associated with a WSI simply failing to deliver. It should therefore
be regularly monitored whether tasks are adequately divided among WSI
participants and affected stakeholders to mitigate different forms of
capture.
2. Have participants clearly defined A proper understanding of the challenges and opportunities for action
the scope and objectives of the requires engagement with affected stakeholders through an ongoing
WSI, as well as its benefits for process that tracks and reports demonstrable progress toward positive
the public interest and for each outcomes and WSI objectives.
participant?
24 August 2015
Principle 5: Be clear and transparent about how the WSI is to be Guiding Questions
governed.
1. Have participants agreed on
WSIs need to establish internal governance mechanisms to ensure that
management (e.g., timing, tasks,
decision making, financial management, and communications meet workplan, oversight, conflict
expectations and are fit for the intended purpose. Decision-making resolution structures, budget
processes should be clear and ensure that all participants are able reporting structures) and decision-
to engage in the process, and that participants providing resources making processes (including
feedback mechanisms), and how
and funding are not given undue influence or special rights. Sharing
to handle communications and
relevant information in a timely manner is essential to ensuring financial issues?
informed participation. Financial arrangements and systems, including
expectations around remuneration and funding flows, should be specified 2. Have they all clearly expressed at
and understood by all WSI participants. Internal audit systems should the outset their expectations about
remuneration and flows of funding?
be established as necessary, and ideally financial arrangements should
Were they properly informed
be disclosed publicly. about financial commitments and
disbursement procedures?
As well as supporting the WSI’s reputation, developing proper systems
ensures that the WSI can deliver according to its stated purpose, that its 3. How is adherence to agreed
funds are directed toward appropriate goals, and that decision making is procedures being effectively
monitored? Are shortcomings
well informed and balanced.
properly addressed?
Guiding Questions Principle 7: Foster an ethos of trust, and establish expectations for
behavior of WSI participants.
1. Have expectations about the WSIs should strive to create an environment that leads to trust and
behavior of WSI participants honesty among WSI participants and affected stakeholders. In doing
been clarified?
so, WSIs can ensure that participants strive to meet their agreed roles and
2. How does the WSI explicitly value responsibilities, and that their behavior leads to positive reputational
honesty? Are agreed procedures outcomes for the WSI. Appropriate behavior ensures that issues of
held as a standard of behavior misconduct that may lead to integrity risks do not become endemic to
(such as a code of conduct)?
the WSI.
3. How have issues of noncompliance
with WSI agreements been Where there is an atmosphere of distrust and dishonesty, integrity risks
addressed? associated with unethical behavior and noncompliance are higher.
Mitigating against these risks will ensure that the WSI is perceived to be
acting in the best and most honest manner possible.
26 August 2015
IV. Applying the WSI Integrity Principles in Practice
The framework below presents a life cycle of the more formalized multi-stakeholder WSIs that are the
focus of this work. In this section, key integrity management activities are mapped against the phases of this
life cycle. For each WSI life-cycle phase, we describe key activities that WSI participants should consider
pursuing to operationalize the principles presented in this guide. The Guiding Questions (introduced in the
previous Section) have been mapped to key activities as signposts, allowing WSI practitioners to determine
where gaps or weaknesses in analysis and processes (or even communications) might need to be addressed.
The authors recognize that in the real world, activities will not always fit precisely within the assigned WSI
life-cycle phase. The aim is to indicate a general flow of key activities in a relative, though not necessarily
linear or prescriptive, sequence. Key activities are hyperlinked to relevant supporting tools that can be found
in Part Two of this guide.
Phase 4: Phase 1:
Completion, Incubation and
Renewal, or Initial Analysis
Upscaling
Phase 3: Phase 2:
Implementation Formalization
• Focuses on activity
implementation, • Begins formalization of the WSI
ongoing monitoring based upon shared participant
and evaluation, and understanding
learning • Defines the key aspects of
the WSI
• Includes developing internal
structures of the WSI to ensure
longterm sustainability and
impact of the WSI
Once some of this initial scoping occurs, usually WSIs expand beyond a small group of organizations to
determine whether the envisioned WSI is the best option to address the local water challenge and serve the
public interest. The WSI would then undergo a thorough context and stakeholder analysis. The participatory
context analysis reviews the nature of the water governance landscape and other contextual factors that
would shape a collective action. The stakeholder analysis focuses on understanding the perspectives, needs,
and interests of key stakeholder groups. This phase results in a decision of whether to pursue the WSI as
well as with whom and how the WSI should engage (as participants or as external stakeholders) to balance
differing interests.
Phase 2: Formalization: This phase focuses on two dimensions of formalization: the objectives and activities
of a WSI and its basic structure. Typically this includes formalizing a shared understanding of local water
challenges and opportunities for action among WSI participants. During this phase, the desired outcomes,
intentions, and public interest benefits of the initiative are specified. The phase should also determine the
geographic scope and scale of the initiative, and the key functions, activities, and/or solutions the initiative
will undertake. This culminates in assigning responsibilities to WSI participants and determining financial
commitments (taking into account participants’ interests and capacities), specifying institutional links, and
planning for any deficiencies.
This phase also focuses on understanding and establishing the degree of formality of the WSI in order to
plan for implementation, the decision-making approach and process, the responsibility boundaries, the
process time frame, and the underlying legal, regulatory, or policy factors that may affect the procedural
aspects of the WSI. This includes undertaking financial planning, establishing the necessary transparency
and accountability measures, building in WSI adaptation provisions, and establishing closure expectations.
As a result, the governance of the WSI is clarified and established.
Phase 3: Implementation: This phase focuses on the actual implementation of project activities, including
ongoing monitoring of stated activities against objectives, evaluating for potential deficiencies and capture
risks, and identifying areas for ongoing learning and amendments to the WSI.
Phase 4: Completion, Renewal, or Upscaling: This phase focuses on evaluating the WSI process and
implementation, as well as determining next steps for a WSI, the plans for its completion, or the necessary
arrangements to ensure its sustainability over a longer time frame.
On the next page is a summary of the key activities mapped against both the principles and the life cycle.
These elements will be further explained in the subsections that follow.
28 August 2015
Phase 1: Phase 4:
Phase 2:
Incubation Completion,
WSI Phase 3:
and Initial renewal, or
Formalization Implementation
Analysis upscaling
Principle 1:
Assess Likelihood
Seek to align, support, and Undertake a of Capture Risks Assess Capture
strengthen public policy that Partipatory and Establish Risks During
advances SWM; be careful Context Mechanisms for Completion/
not to undermine public Analysis Monitoring and Transformation
institutions or Oversight
water governance.
Principle 3:
Be clear and transparent
about the roles and Analyze WSI
Assign Appropriate
responsibilities of WSI Partipant
Roles and
participants, and ensure Records and
Responsibilities
that their capabilities are Incentives
adequate (or are sufficiently
developed) to fulfill them.
Principle 4:
Be clear and transparent Undertake a Regularly
Define Scope,
about water challenge(s) Participatory Question and
Objective and Public
being addressed by the WSI, Context Verify Theory of
Interest of the WSI
as well as the agreed scope, Analysis Change
and intended benefits.
Establish Equitable
Principle 5: Decision-Making Monitor WSI
Be clear and transparent Structures, Participation
about how the WSI is to Communication, and Adherance to
be governed. Finance & Determine Governance
Corporate Form
Participatory Final
Establish M&E
Principle 6: Communicate Evaluation and Audit
Systems
about WSI
Track outcomes against the Embed activities
Establish an Exit
stated objectives of the WSI. Performance and outcomes into
Strategy
existing institutions
Principle 7:
Foster an ethos of trust, and Clarify Expectations
establish expectations for of WSI Behavior
behavior of WSI
participants.
30 August 2015
Key Activites
Identify and map stakeholders affected by the (or their legitimate proxies), as well as those with a
significant ability to influence WSI outcomes.
▨▨ The stakeholder mapping should be used as an opportunity to assess the capacities of different stakeholders and their ability to
contribute to the WSI
How? Identifying relevant stakeholders and understanding their perspectives and interests is known as stakeholder
mapping. Utilize Tool 3: Mapping a WSI’s Key Stakeholders to identify affected and influential stakeholders, in order to
take into account their legitimate interests and knowledge.
Undertake an initial analysis of WSI participants’ track records, incentives, and intentions.
How? To understand these issues, an initial due diligence process should be conducted. It involves the systematic
collection and analysis of information on how a particular organization is managed or how a company does business.
The investigation reveals whether a potential WSI participant commits to professional and ethical business practices,
and uncovers the risks and opportunities involved in a potential initiative. It also reveals conflicts of interest and
participants’ intentions. Utilize Tool 4: WSI Participants Due Diligence Investigation to carry this out. WSI participants
may undertake an exercise that leads to a “declaration of interest” that clearly states the benefits respective
participants expect to realize from engaging in the WSI.
Undertake a participatory context analysis for the WSI to understand ongoing public sector–led efforts
and policy objectives related to sustainable water management, and evaluate the implications for the
WSI.
▨▨ As part of this analysis, WSI participants should thoroughly explore and document alternative options to the WSI, and evaluate
if and how the WSI option is best suited to address the identified water challenges, opportunities, and underlying factors.
▨▨ The analysis should explicitly specify the water-related challenges and opportunities and the underlying factors or gap(s) the
WSI seeks to address. In doing so, it should delineate how the WSI aligns with public policy objectives and strategies, and is
expected to yield public interest benefits related to water. This entails assessing potential positive or negative impacts of the
WSI on the resources of government institutions and how they can be maximized or mitigated.
How? Utilize Tool 5: Assessing the Context of a WSI, which provides practitioners with a structured approach to
assessing the wider environment of the WSI and understanding the root causes of the water-related challenges it
aims to tackle. The tool lays out in a stepwise approach to undertaking such a process, including how to incorporate
stakeholder perspectives, key questions to ask, and overall tips.
32 August 2015
Key Activities
Determine whether and how affected stakeholders (or their proxies) can be appropriately represented
in the WSI.
▨▨ The WSI should strive to ensure that participants adequately reflect the range of potentially affected interests. Where
affected stakeholders (or their proxies) cannot be represented as WSI participants, establish an appropriate ongoing external
engagement mechanism that enables affected stakeholders to provide periodic input to help shape the design of the WSI and
its implementation.
▨▨ The effort should involve understanding who the relevant voices are (or their proxies, as appropriate) and provide a process that
focuses on understanding the views of affected stakeholders, garnering their input, and sharing relevant project information.
Proxies for stakeholders need to have legitimacy and authority to represent those interests.
How? Stakeholder engagement provides insights into the needs and wants of stakeholders who either have the
power to influence the implementation of the WSI or are affected by it. A participatory planning process builds
legitimacy and credibility for the WSI by ensuring that a range of voices are heard. Such a process brings new ideas
and directions that will require the WSI to be flexible and adjust initial ideas, objectives, and intervention strategies.
WSIs are iterative learning processes that require dedicated attention to improve participation through subsequent
stages of its life-cycle. Utilize Tool 6: Support Materials for a Participatory Planning Process for insights.
Define among WSI participants the scope, objectives, and public interest benefits of the WSI, as well as
the benefits of the WSI for respective participants.
▨▨ It is important that participants specify the change that the WSI seeks to achieve against the current state of water resource
management.
▨▨ Once preliminary decisions are taken, WSI participants should communicate and validate with affected stakeholders the
justification for the WSI.
How? Utilize Tool 6: Support Materials for a Participatory Planning Process and Tool 7: Basics for WSI Monitoring
and Evaluation to help participants determine how to best hold these discussions. These tools offer pointers on key
elements to discuss and how to effectively communicate with stakeholders.
Complete analysis of WSI participants’ track records, incentives, and intentions, as well as their
respective capabilities and constraints.
How? A WSI participant due diligence process involves the systematic collection and analysis of information on how
a particular organization is managed or how a company does business. The investigation reveals whether a potential
WSI participant commits to professional and ethical business practices, and uncovers risks and opportunities
involved for the potential initiative. It also reveals conflicts of interests and participants’ intentions. Utilize Tool 4: WSI
Participants Due Diligence Investigation to carry this out. For participants that also act as funders, also use Tool 8:
Financing and Audit Protocols to mitigate risks of capture, misleading expectations, or bad perceptions.
Assign among WSI participants suitable roles and responsibilities for all activities, coordination tasks,
processes, and procedures.
▨▨ At this time, oversight responsibilities (and potentially third-party controls) should be established to ensure that WSI participant
oversight can be fulfilled properly.
How? Effective and successful WSIs typically require that a broad array of functions are fulfilled. At the same
time, WSI participants bring with them a broad array of expertise and resources, as well as areas in which they
have limited experience and capability. As such, well-defined roles and responsibilities among WSI participants
that build on their core competencies or are aligned with their main interests are critical to project success. To
effectively assign and manage roles, utilize Tool 9: Managing Roles and Responsibilities within a WSI. To ensure that
the roles and responsibilities are effectively carried out, oversight mechanisms may be needed. The mechanisms
can be used to oversee the WSI’s operations or implementation of specific WSI agreements and verify compliance
with agreed procedures. Oversight mechanisms should be specified in the written agreements that govern a WSI to
ensure transparency and to establish a reference point to hold WSI participants accountable if needed. Use Tool 10:
Establishing Written Agreements for a WSI. To understand how to establish oversight mechanisms that go beyond
internal measures, refer to Tool 11: Options for Independent Oversight.
Jointly identify and establish equitable decision-making structures and processes within the WSI, ensure
that effective communications occur among WSI participants and with affected stakeholders, and clarify
how financial issues will be handled.
▨▨ It is important to consider linking the decision-making processes to the purpose and objectives of the WSI.
▨▨ This includes establishing clear expectations about remuneration and flows of funding at the outset, and informing participants
about financial commitments and disbursement procedures.
▨▨ It is important to develop clear communication channels with affected stakeholders about the type of information that will be
communicated, and the intervals and mechanisms for communications.
How? The purpose of a memorandum of understanding (MoU) within a WSI is to formally agree on the shared
objectives, roles, and ground rules of an initiative, and includes defined decision-making structures. Even where
an MoU is not legally binding, it represents an important mutual commitment, should be signed at the senior level
within each partner organization, and should have regular performance reviews. See Tool 10a: Developing a WSI
Memorandum of Understanding. In addition, financing and auditing protocols for WSIs may also help participants
comply with moral or legal duties related to funding arrangements. For relevant guidance, also see Tool 8: WSI
Financing and Audit Protocols.
How? Developing a shared understanding of integrity in a specific WSI is an essential exercise in stakeholder
collaboration that serves to build trust among actors, share experiences and good practices, identify shared values,
and clarify expectations. As a central reference, a Code of Conduct guides WSI participants when dealing with ethical
dilemmas and grey areas in decision-making and engagement processes. Utilize Tool 10b: Developing a WSI Code of
Conduct.
Explore organizational forms that align with the purpose and nature of the WSI.
▨▨ The right organizational form can provide legal certainty and establish a linkage to existing regulatory frameworks and their
subsidiary standards and/or rules relating to aspects of integrity (e.g., financial accounting and contracting). It also enables the
use of legal accountability mechanisms in case of disputes.
How? The overarching purpose of the organizational form is to support joint activity in delivering the objectives of
the WSI. The organizational form needs to be flexible to allow the exploration of opportunities within the WSI before
development and implementation of the WSI goals and objectives. For guidance on options for establishing a form,
utilize Tool 10: Establishing Written Agreements for a WSI.
34 August 2015
Key Activities
Assess the likelihood of policy capture and establish adequate safeguards to reduce capture risks.
▨▨ Such an assessment will inherently increase understanding among WSI participants as to what constitutes capture and will
raise awareness of relevant risks for the public agencies involved in the WSI, as well as for the WSI as a whole.
How? “Capture” can be understood to occur when discretionary decision-making or policy processes become
systematically distorted or biased in favor of some interests over others due to structured imbalances in power and
influence. The undue influence or “capture” of public policy, public funds or regulatory processes, or of the water
resource itself are perhaps the most significant integrity hazards facing WSIs. Identifying these hazards and marking
out with “red flags” where and how capture might happen is a first step toward mitigating capture risks. Utilize Tool
1c: Red Flags to Assess and Monitor Capture Risks to effectively implement a process for assessing capture risks.
Subsequent to the assessment, establish a mechanism for monitoring and oversight of policy capture
risks.
How? The “exit strategy” is the plan that clarifies how the WSI will end or transform (e.g., once goals have been
achieved; at the end of the project or funding cycle) or that makes provision for the withdrawal of participant
organizations. Fostering sustainability and mitigating risks of failure lie at the heart of this strategy. It needs to be
designed jointly from the onset and revisited regularly as the initiative evolves. Find additional guidance for developing
an exit strategy by using Tool 12: Developing an Exit Strategy.
Establish an M&E mechanism that enables WSI participants to understand both expected and
unexpected outcomes, and determine whether the WSI is meeting its stated objectives.
The M&E mechanism can be a key tool in the ongoing implementation of a WSI, and among other benefits, it
allows participants to continually monitor for new integrity risks that may arise. It also enables learnings from the
mechanism to be integrated into future WSI activities.
How? Monitoring is a periodic and structured activity where priority information about the WSI is collected to assess
performance against the defined objectives. Evaluation involves analyses of the WSI’s activities, characteristics,
and outcomes to determine the merit of the initiative and to generate lessons for the future. Tool 7: Basics for WSI
Monitoring and Evaluation provides an overview of the importance of developing M&E jointly with WSI participants.
36 August 2015
KEY ACTIVITES
Monitor WSI participant representation and engagement of affected stakeholders over the course of the
WSI, and take action to balance interests where needed.
▨▨ Responsiveness, attendance at meetings, and engagement in the implementation of activities and in the
coordination of the initiative should be monitored in regular intervals, to track stakeholder engagement
throughout the implementation of a WSI.
Monitor WSI participant adherence with and exceptions to defined governance procedures.
▨▨ Ensure that issues of noncompliance with WSI agreements are addressed in a timely and appropriate manner.
Monitor and audit the adherence to financing and audit protocols, and refine those in case provisions are not
suitable or sufficient.
Regularly question and verify the WSI’s theory of change and adapt/improve to ensure that it is algned
with stated WSI objectives and contributes to sustainable water management more gnereally.
How? Tool 2: WSI Model — A Template to Describe the Logic of WSIs provides a template to capture in a nutshell
how a WSI will operate and generate shared benefits. It provides the basis for developing a strategy to improve the
impact and integrity of the WSI. The WSI model provides a structure through which WSI participants can clearly
and transparently discuss key aspects of the WSI so they can understand whether the WSI is meetings its theory of
change.
How? Throughout this stage, the effective usage of monitoring and evaluation will be necessary to understand how
well the WSI is meeting its stated objectives. Agreement on a shared goal, outcomes, and outputs, and systematic
collection and assessment of delivery against these is vital to enable learning, informed decisions, and improved
practice in future, for internal and external accountability against the resources used, and for appraisal of WSI
effectiveness, efficiency, and sustainability. Further guidance on development and use of monitoring and evaluation
can be found in Tool 7: Basics for WSI Monitoring and Evaluation.
38 August 2015
Key Activites
Undertake a participatory final evaluation and financial audit of the WSI, and communicate results to
affected stakeholders.
▨▨ The evaluation should focus on understanding how well the WSI met its stated objectives and its ability to
bring about increased SWM.
Engage affected stakeholders in the decision-making process for renewing, upscaling, or completing
the WSI.
How? Stakeholder engagement provides insights into the needs and wants of affected stakeholders who have the
power to influence the implementation of WSIs or are affected by a WSI. Several relevant guidance documents
are provided in Tool 6: Support Materials for a Participatory Planning Process. The outcomes of a final (ideally
independent) evaluation should be used to inform the decision making concerning renewal or completion of the WSI.
Determine how to best ensure that activities and outcomes are appropriately embedded into existing
institutions.
How? The exit strategy is the plan that clarifies how the WSI will end or transform (e.g., once goals have been
achieved, or at the end of the project or funding cycle). Fostering sustainability and mitigating risks of failure lie at the
heart of this strategy. It must be designed jointly from the onset and revisited regularly as the initiative evolves. For
more guidance see Tool 12: Developing an Exit Strategy.
Establish a process to monitor and evaluate capture risks during the completion and/or transformation
of the initiative.
How? Capture can be understood to occur when discretionary decision-making or policy processes become
systematically distorted or biased in favor of some interests over others due to structured imbalances in power and
influence. The undue influence or “capture” of public policy, public funds, or regulatory processes, or of the water
resource itself, is perhaps the most significant integrity hazard facing WSIs. Identifying these hazards and marking
with red flags where and how capture might happen is a first step toward mitigating capture risks. Utilize Tool 1c: Red
Flags to Assess and Monitor Capture Risks to effectively implement a process for assessing capture risks.
For completion, establish appropriate mechanisms for managing residual finances and assets from the
initiative.
When renewing or upscaling, initiatives may also consider (a) undertaking activities under Phase 1 to understand the
continued need for the WSI given current realities, and (b) undertaking an integrity risk assessment to ensure that
integrity management is embedded in the WSI’s ongoing implementation.
40 August 2015
Suite of Supporting Tools
The following suite of tools provides practical insights and a range of supporting products that can help
practitioners manage WSI integrity issues, with a view to improving the overall governance and impact of
such initiatives.
The tools support practitioners in implementing the key activities outlined in Part One–Section IV of the
guide. They include diagnostic tools to help WSI participants identify and analyze integrity risks in the
context of their specific WSI, as well as action-oriented tools to mitigate these risks. This guide is intended
to assist practitioners in managing integrity as part of overall WSI management (as opposed to making it an
additional undertaking), and thus many of the tools in this toolkit (e.g., Tool 5: Assessing the Context of a WSI
or Tool 10a: Developing a Memorandum of Understanding) can be thought of as basic project management
tools that are much broader than integrity. The summary table at the outset of each tool highlights how it
can be used to safeguard integrity and the key aspects that deserve special attention in this regard. Moreover,
some of the tools, like Tool 1b: Facilitator’s Guide for Participatory Integrity Risk Management Exercises, provide some
ideas for integrating these integrity issues into broader ongoing activities for greater efficiency.
This toolbox does not include all the possible tools that could be used to manage high levels of integrity in a
WSI, nor is it intended that every WSI using this guide would need or want to implement all of the tools in
Part Two. Rather, the tools in Part Two focus on how some of the most commonly encountered WSI integrity
issues can be addressed. They can be used a la carte, in some cases offering a number of options to choose from
based on an assessment of where the WSI stands, what the most pressing integrity issues are, and into which
current processes integrity aspects can be integrated.
Where possible, the tools provide “off-the-shelf” templates, checklists, minimum standards, or sample clauses
for agreements. Nonetheless, they are meant to be used as approximate guidance (not prescriptive blueprints)
to assist WSI practitioners in establishing context-specific solutions. In adapting tools to their specific
context, WSI participants will need to consider the type and size of their partnership, local capacities,
available resources, and specific risks facing their WSI. Hence, practitioners are invited to shape these tools as
necessary or simply use them as inspiration to find their own solutions. In doing so, WSI participants need
to balance the need for formal arrangements with more trust-based cooperation, depending on the local
water management framework and the relationships among themselves and with affected stakeholders.
In the process of putting this guide into practice in a growing number of WSIs, the suite of tools will no
doubt further evolve. New tools or variations can be developed, lessons on what’s achievable with a tool can
be drawn, and examples can be provided to augment the tools.
Establishes the most important integrity risks that undermine the WSI’s contribution to
sustainable water management, and provides the basis for systematically managing and
mitigating integrity risks.
Purpose
▨▨ Raises awareness of critical aspects and weaknesses that undermine the impact of the WSI.
▨▨ Analyzes when a WSI may be misused to divert public resources and priorities or for undue
influence over the water sector.
Possible
WSI participants
Users
The purpose of conducting an integrity risk assessment is to identify the WSI’s specific integrity risks
and, in turn, to identify the measures needed to ensure high levels of integrity among its participants,
for the governance and management of the initiative, and for its relationship with the local context and
environment. Understanding which integrity risks are most likely and hazardous serves as the basis for
efficient and effective management.
Given the diversity of WSIs, the most appropriate timing and approach to analyzing integrity risks should
be decided on a case-by-case basis. However, it need not be an onerous or resource-heavy process; it is simply
about scoping out the potential integrity problems that a WSI could face. The earlier, more inclusively, and
more thoroughly this can be done, the better. The approaches below can help WSI participants understand
integrity risks. Tool 1a: WSI Integrity Risk Assessment builds on desk reviews and interviews of key informants to
help generate the most relevant information. Integrity risks can also be assessed as part of a larger meeting
or over the course of several regular management workshops. Tool 1b: Facilitator’s Guide for Participatory WSI
Integrity Risk Management Exercises provides a sequence of exercises that can guide WSI participants in
analyzing integrity and other risks a WSI may face. Facilitation by an independent and experienced third
party, using a well-adapted process, will help create a safe place for stakeholders to share their fears and
anxieties about integrity issues the WSI may encounter and to build trust and openness. Generating a shared
understanding of integrity risks is a very valuable process in itself, and only in very challenging contexts may
it be more appropriate for WSI managers to conduct the assessment in private.
The undue influence or “capture” of public policy, public funds, or regulatory processes, or of the water
resource itself, are perhaps the most significant integrity hazards facing WSIs. Tool 1c: Red Flags to Assess and
Monitor Capture Risks provides detailed guidance not only for WSI initiators and participants, but also for
affected stakeholders to identify these hazards and highlight where and how capture might happen.
42 August 2015
Tool 1a: WSI Integrity Risk Assessment
A guide on conducting a WSI integrity risk assessment that supports identification of the priority
Tool
risks facing the initiative, and helps evaluate appropriate risk mitigation measures.
Related Key
Understanding integrity risks facing WSIs.
Activity
Inventory integrity risks related to the outcomes, participants, and processes that govern a WSI:
Purpose ▨▨ Raise awareness of critical aspects that undermine the impact of the WSI.
▨▨ Identify mitigation measures and responses.
Possible WSI initiator(s) or as a group exercise among initial WSI participants; at later phases all affected
Users stakeholders may be involved.
From internal exercise by WSI initiator(s) to comprehensive assessment (e.g., as part of context
Level of
analysis or general risk management); at the outset of an initiative, risks should be scoped as
Effort
widely as possible.
Especially during 1: Incubation and Initial Analysis and 2: Formalization, but can be beneficial
WSI Phase
across all WSI phases.
An integrity risk assessment may be carried out at any phase in a WSI, though it will be most beneficial to do
in the Incubation and Initial Anaylsis or Formalization phases, and to review the assessment and efficacy of
integrity management throughout the life cycle of a WSI at specific intervals. Although risk assessment can
be done as a theoretical, desk-based exercise, it is preferable to increase rigor and ownership by conducting
informant interviews with WSI participants and affected stakeholders.
To support prioritized mitigation responses, integrity risk areas emerging through the assessment can be
ranked according to the magnitude of the hazard they pose and the likelihood of their occurrence. The
nature of each integrity risk area should be elaborated using examples. Options for mitigation should also be
set out, drawing on WSI participant and affected stakeholder suggestions. As stated it is likely to be most
efficient to address integrity risks as part of a wider risk management exercise for the WSI.
Five steps to guide the development of an integrity risk assessment tool are suggested below:
▨▨ The strategy for applying the integrity risk assessment should include thinking
about when, how, and with whom to work in terms of both stakeholders and
Step 1: Decide an facilitators.
Optimal Strategy ▨▨ The selected strategy should streamline and integrate the assessment with
other phases or activities (i.e., WSI planning and review workshops or during the
evaluation).
▨▨ The WSI integrity risk register should be monitored and reviewed as part of the
Step 5: on-going WSI management cycle, with clear lines of responsibility, actions and
Monitor and Review timescales for mitigation, assessment of effectiveness, and appraisal of new
risks, along with resources to support the process.
44 August 2015
Guidance for analysis of integrity risks of WSIs
The risk assessment should draw on the perspectives of those participating in, or potentially affected by,
the WSI through interviews and/or workshop input to identify the nature of risks faced, their relative
significance, and to solicit advice on how they can be managed. The following questions can be used to guide
stakeholder discussions:
1. What are the main integrity challenges facing the future/current/past WSI? Consider in
turn the cause and nature of risks to participant credibility, fair process, and achieving good
outcomes.
2. Who is at risk because of these challenges? Could the risks potentially impact participants,
the public, communities, water institutions, or the environment?
3. How severe is the impact of the risk? Are the impacts temporary, long-term, or irreversible?
Minor, severe, or extreme?
4. What is the likelihood of the problem occurring? Given the context, the nature of the WSI,
and the partners, is there a strong, medium, or weak chance that the integrity risk will actually
happen?
5. How can the project prevent or manage the integrity risks? How can it ensure that
participants are credible, processes are fair, and outcomes appropriate?
6. How effective are these mitigation measures likely to be? Is it realistic to assume that the
integrity risk mitigation measures will be effective? Have they worked well in the past? What has
not worked so well and why?
Group responses to these guiding questions should be used to prioritize and plan mitigation actions based on
the severity of the hazard and likelihood of occurrence, and to populate the WSI risk register and mitigation
plan. The guiding principle here is that a hazard that can potentially exert negative impacts beyond the
confines of the WSI itself—on people, the environment, institutions, or society—is assigned a higher hazard
score than those likely to impact only the WSI. Risks with either a high likelihood or a high impact warrant
special attention and effort to reduce, remove, manage, or monitor risk. The risk register and rating matrix
below should be expanded to help WSI participants and affected stakeholders to systematically consider
risks and the adequacy of mitigation responses. The risk register (Table 2) has been partially filled for
illustrative purposes only.
In applying and interpreting these tools, a common sense and proportionate approach is encouraged. The
integrity risks facing WSIs can be very real and immediate, affecting large numbers of vulnerable people or
the environment and must be seriously considered and managed in a structured way. However, the nature
and severity of integrity risks will vary depending on the nature and context of the WSI. Those with long-
term experience of the contexts at hand and those involved with and affected by the initiative will be well
positioned to establish the relative seriousness of risks and the adequacy of responses.
b. Specific risk identified: The track record of one or more participants damages the integrity of
the WSI.
c. Possible impact identified: The public or political credibility and therefore effectiveness of
the WSI could be undermined if one or more participants are severely contravening pollution
control law.
d. Assess likelihood: Drawing on Table 2, participants agree that because they have thoroughly
vetted and ensured transparency of internal control mechanisms and compliance by all partners
in the WSI, the likelihood of this occurring is low: “unlikely — a possibility of occurrence”. A
low score of 1 is therefore assigned, with a heat-based color scheme denoting levels from low
(yellow), medium (orange), and high (red).
e. Assess impact: Based on discussion, and bearing in mind the nature of the WSI and its context
(which concerns water quality in a severely polluted basin where people and ecosystems are
impacted), it is decided that the impact of a partner causing serious pollution on the integrity
of the WSI would be significant (orange, score 2) because of the long-term impact on the
initiative.
f. Mitigation actions (specifying who, what, and when): Actions to reduce the likelihood or
impact of the integrity risk are specified here and include Tool 4: WSI Participants Due Diligence
Investigation. Who does what and when is specified to remove ambiguity and ensure that
mitigation actions can be tracked.
g. The tolerability of the risk is considered based on this previous profiling of the risk and
agreement on the likely efficacy of the mitigation measures.
h. Ownership of risk management and reporting is assigned, and a review period specified; in
this case to the WSI initiator, who will review the risk and update the status of mitigation
actions every six months.
The risk-rating matrix in Table 3 can be used to help varied audiences score and prioritize integrity risks
based on likelihood of occurrence and impact of hazard presented. The function of likelihood and impact
scores can be calculated to indicate risk severity.
46 August 2015
Table 2: Simplified Example of a WSI Integrity Risk Register
g. h.
f. Is the risk Risk
b. Mitigation tolerable with manager
a. Specific c. Possible d. e. actions (who, mitigation? and review
Risk area risk impact(s) Likelihood Impact what, when) (Y/N) period
WSI initiator to carry
out thorough local due
diligence check on formal
partners and require full
disclosure on compliance
Partners prior to MoU signing.
undermine public Yes —
credibility of Select appropriate Dependent on
the WSI and partners based on nature nature of WSI WSI initiator:
Track co-partners of WSI. and partners
Participants 1 2 report every
record because of — best judged 6 months.
mismanagement, Test credibility with focus locally by WSI
ongoing pollution, group. participants and
non-payment of stakeholders
tax, or corruption. Draw up detailed
partnership agreement.
Agree on a public position
on partner performance
and existing strategies.
IMPACT: IMPACT:
IMPACT: Moderate
Significant Catastrophic
1 2 3
Likely: Will probably occur 3 3 6 9
Possible: May occur at
2 2 4 6
some time
Unlikely: Will probably not
1 1 2 3
occur
1 — Low: Monitor and manage using routine procedures.
2 — Medium: Management responsibility must be specified.
3, 4 — High: Senior management attention, detailed planning, and monitoring needed.
6 — Very High: Immediate action required to explore suitability of initiative.
9 — Extreme: Unacceptable risk.
The following matrix provides a reference to evaluate the level of impact of specific integrity risks of WSIs:
IMPACT: IMPACT:
IMPACT: Moderate
Significant Catastrophic
Beyond the confines of the WSI — impacts on:
Temporary or localized
n/a (any negative impact Permanent or widespread
detriment to people’s
People on people is significant or reduction in health,
health, livelihoods, or well-
catastrophic) livelihoods, and well-being.
being.
n/a (any negative impact
Temporary or localized Permanent or widespread
Environment on environment is
detriment to environment. detriment to environment.
significant or catastrophic)
Long-term undermining
Some competition with
Undermining of local of institutional functioning
Institutions local institutions for
institutional performance. at local, basin, or national
authority or resources.
scale.
Internal to the WSI — impacts on:
Inefficiency and poor Creates cost distortions or
Economy Ineffective use of budget.
value for money. gross waste of funds.
Local mention and Persistent national International concern,
scrutiny only. Ability of concern and external government inquiry, or
Reputation
partners and initiative to scrutiny. Long-term brand sustained adverse media.
operate unaffected. impact for initiative. Brand Impact on partners.
Impact resulting in
Protracted unavailability
Some impact on delays reduced performance
Capability of critical skills and people
and system quality. of partners or initiative.
external to the initiative.
Targets not met.
Further reading:
- Voluntary Services Overseas (VSO). 2004. Participatory Approaches: A Facilitator’s Guide. London: VSO. http://www.
participatorymethods.org/resource/participatory-approaches-facilitators-guide.
- Department for International Development (DIFD). March 2003. Tools for Development: A handbook for those engaged
in development activity, Version 15.5.
- http://webarchive.nationalarchives.gov.uk/+/http:/www.dfid.gov.uk/Documents /publications/
toolsfordevelopment.pdf.
48 August 2015
Tool 1b: Facilitator’s Guide for Participatory Integrity Risk Management Exercises
The exercises should be embedded into the regular consultations and management
Related Activity
activities of a WSI and can be used to share the integrity risk assessment.
Initiate a change process with participants to jointly enhance the WSI’s integrity:
Identify integrity risks that are most relevant to a given WSI, given its scope and
Purpose context.
Develop a workplan that specifies how activities that are most relevant at a given
phase of a WSI will be implemented.
Participatory integrity risk management exercises are meant to initiate a change process in which
participants jointly enhance the WSI’s integrity. In existing WSIs that have not yet followed an explicit
integrity management approach, the following exercises can serve as a starting point to align the
WSI with these integrity management guidelines. The sequence of exercises is meant to facilitate a
step-wise process to identify the key activities and the supporting tools that enhance the initiative’s
integrity most effectively. To use time effectively, exercises should be combined and adapted to include
other risks a WSI may be facing and should be embedded into the overall management approach of
the initiative. For WSIs that have integrated systematic risk management from the planning phase, the
exercises serve to take stock, refine, and complement the measures put in place, plan next steps, and
further sensitize participants.
Ideally these integrity risk management exercises would be included in a larger management workshop.
In case a comprehensive risk assessment (Tool 1a) has been carried out, the results can be shared in
Exercise 3 and provide guidance for the subsequent exercises. Where this approach is not feasible,
individual exercises can be integrated into regular working meetings of the WSI.
The exercises should ideally involve all the active participants of a WSI. Wherever possible, the
integrity management exercises can further be used to engage and understand critiques and other
affected stakeholders.5 As ensuring integrity in WSIs is closely linked to the overall development of
such initiatives (i.e., how they are managed and governed), it is recommended to describe the logic of a
WSI using the Tool 2: WSI Model, and to use this description as a central reference point throughout the
subsequent exercises. The outcome of the exercises is a workplan that specifies how the most relevant
activities will be implemented, how they will enhance the integrity and impact of the WSI, and which
risks will be addressed. The tool comes with a set of facilitation materials, developed to convey the
content of this guide and to enable effective learning with a diverse group of participants (see the
Overview at the end of this Facilitator’s Guide). To analyze other risks a WSI may be confronted with,
these materials should be complemented and adapted on a case-by-case basis.
5 Otherwise, the outcomes of the workshop should be communicated with other affected stakeholders to activate them as
potential external partners for activities.
The six integrity risk management exercises are interlinked, which should be taken into account when
implementing them over the course of several working sessions. The introduction to integrity management
for WSIs (Exercise 1) and the development of the WSI Model (Exercise 2) can be implemented as stand-alone
activities that raise awareness about integrity risks and that structure information on the WSI’s theory
of change inclusively and transparently. If there exists a well-structured description of the WSI’s logic,
participants can combine their efforts to prioritize integrity risk areas (Exercise 3) and further analyze the
risks using the related guiding questions (Exercise 4). Identifying key activities to enhance the WSI’s impact
and integrity (Exercise 5) and developing a road map for action (Exercise 6) build on the results of previous
exercises.
The sequence of these exercises is summarized below, highlighting their purpose and scope. Further
guidance for the workshop facilitation is provided in the Facilitator’s Guide below.
6 The facilitators’ guide therefore combines the methodologies used in: (1) the Integrity Management Toolbox: Janek Hermann-Friede,
Michael Kropac, Sarah Achermann, Johannes Heeb, and Lotte Feuerstein, Integrity Management Toolbox for Water Service Providers —
Manual for Facilitators (Berlin: cewas, WIN, and GIZ, 2014), http://www.waterintegritynetwork.net/publications/; and (2) the Annotated
Water Integrity Scan (AWIS): Jan-Teun Visscher and Janek Hermann-Friede, AWIS Facilitator’s Guide (Berlin: WIN and Transparency
International, 2011), http://www.waterintegritynetwork.net/publications/.
50 August 2015
▨▨ This module is about setting the scene: familiarizing participants with the topic,
setting the tone of the workshop, and clarifying questions and expectations.
▨▨ An integrity management workshop brings WSI participants together to jointly
Exercise 1:
analyze the integrity status of their initiative and prioritize key activities to be put in
Integrity Management
place or strengthened to increase the WSI’s impact.
Introduction (~1hr)
▨▨ After the scope of the workshop has been clarified, it is important to introduce the
seven operating principles included in this guide and how they frame the values and
expectations that constitute integrity in WSIs.
▨▨ In this module participants assess the likelihood and hazards of different integrity
risks related to the building blocks of the WSI Model (or other description of the
initiative). Making this connection allows for an analysis in which risks are linked to
Exercise 3: participants, to the WSI governance, and to the WSI’s context.
Prioritizing Integrity
▨▨ Furthermore, the group will develop an understanding of how integrity risks affect
Risk Areas (~1.5 hrs)
the impact and performance of a WSI and identify which are the most harmful risks.
▨▨ Based on this assessment, the group will prioritize the three or four most important
integrity risks.
▨▨ Participants identify the specific strengths and weaknesses in the prioritized integrity
risk areas by discussing the key guiding questions that are linked to each priority risk
area.
▨▨ These questions are individually answered and then jointly analyzed by the
Exercise 4: participants in a facilitated discussion. During the discussion, qualitative information
Assessing Strengths about the WSI is captured and documented as annotations to the different
and Weaknesses questions.
(~2.5 hrs) ▨▨ If documented properly, the outcomes of this exercise will serve as a baseline from
which to evaluate the development of the WSI’s governance and integrity over the
course of its life cycle.
▨▨ An inquiry-based approach provides for a constructive dialogue in assessing these
sensitive issues and contributes to harmonizing the understanding of the WSI.
▨▨ In this module, participants select the most important activities to enhance the
Exercise 5: integrity of their WSI based on the strengths and weaknesses identified in each of
Selecting Key the priority risk areas.
Activities (~1.5 hrs) ▨▨ The selected key activities are linked to the WSI Model to establish clear objectives
that enhance the integrity and impact of the WSI.
▨▨ In this module participants map out implementation steps for the identified key
Exercise 6: activities against a timeline and agree on responsibilities and practical next steps.
Developing a Road ▨▨ To close the loop back to the values that constitute integrity in WSIs, participants
Map (~2 hrs) analyze how the key activities they planned contribute to complying with the
operating principles.
2.1. Introduce the WSI Model canvas concept and its ten building blocks, WSI Model PowerPoint
15
with the help of the introductory PowerPoint presentation. Distribute the Explanation sheet for the
min.
WSI Model explanation sheet to the participants. WSI Model
52 August 2015
Exercise 3: Prioritizing integrity risk areas
3.3. Ask the participants to prioritize the three risk areas they think their WSI
should address most urgently. A suggested approach:
Using the score sheet for integrity risk areas, each participant scores the
Score sheet for integrity
likelihood and hazard of the risk areas according to their perception.
30 risk areas
min. The facilitator processes the scoring results anonymously. The integrity risk
Risk matrix on brown
area color cards are then placed in the risk matrix according to the results.
paper
Ask the participants to discuss the results and whether they agree with the
prioritization. Based on the discussion, the group may adapt the prioritization
and document why. (For options, see footnote.1)
Have a joint understanding of their WSI’s strengths and weaknesses related to the most important risk areas
and guiding questions
Have documented the status of integrity and will have mapped strengths and weaknesses in the priority risk
areas of the initiative.
time activity materials
4.1. Turn around the three priority risk cards and put each on one
box of the brown paper. Ask the group to pick from the board the Color cards with guiding
cards with guiding questions indicated on the risk cards.2 Put the questions
20
guiding questions in the box of the relevant risk. In case of new
min. Pin board with brown paper
risk areas (added during the previous exercise, without pre-defined
guiding questions), participants should establish a set of three to five divided into 3 boxes
questions related to the selected risks.
4.2. Hand out scoring sheets with the guiding questions and
answering options for the priority risk areas. Ask the group to go
through the guiding questions and answering options, and clarify any
unclear terms. Explain to the participants that the answering options
shall provide only a rough picture and that the specific situation Scoring sheets for the guiding
30 of the WSI will be discussed in the next step. The participants questions related to the priority
min. should then anonymously answer the questions using the available risk areas
answering options.
During a 5-minute break, the facilitator collects the scoring sheets
and generates the average scores based on the answers to each
question.
10 4.3. Explain the same hat approach (see box) and the annotation Presentation to introduce the
min. process around the answers. same hat approach
4.4. The facilitator presents the average scoring results for the first
risk area by writing the scores next to the cards with the guiding
Color cards and pens for each
questions for that risk area.
participant
Depending on the group, the facilitator may kick off the dialogue
Pin board with brown paper
by opening the floor to an initial discussion. You can then do a card
divided into 3 boxes
90 exercise by asking the participants to write down the arguments
min. for the level below the average scores (weaknesses), and after AWIS facilitator’s guide
having discussed these cards, do another round for the level above (Visscher and Hermann-
(strengths). Friede, 2011, pp. 22–24) for
instructions for the facilitation
This exercise is repeated for each of the guiding questions. The
process
output is a map of strengths and weaknesses for each of the
prioritized risk areas.3
54 August 2015
Adopting the same hat approach
Exercise 5: Selecting key activities
WSI participants have different
By the end of this exercise, participants will: types of information, which may
affect their perception of the integrity
Have identified key activities to enhance the impact and integrity
situation. For example, consider the
of their WSI. guiding question: How well have risks
Have analyzed how the key activities improve their WSI Model. with regard to public sector collusion
and policy capture been identified? Are
time activity materials they being managed? Average score of
1.8 implies that some participants may
5.1. Turn around the guiding questions have given an answer that scores 1 and
cards and ask the group to add the related others have given an answer scoring of
15 Color cards for
supporting tools (listed on the back of the 2 or higher. The corporate partner may
min. key activities
cards) to the annotations that have been have spent significant time discussing
documented. capture risks with the WSI manager,
but other WSI participants are not
5.2. Ask participants to reflect on the map of aware of this analysis and provide
strengths and weaknesses, and ask them if lower scores. When discussing their
they know any other measures that can help. Pin board perception with others, several
Add cards with additional measures to the list. with map of participants may tend to stick to their
strengths and opinion and will try to convince the
Ask participants to analyze how the supporting weaknesses for other party. This may lead to a long
30 tools and suggested additional measures will the prioritized debate with winners and losers.
min. tackle the identified weaknesses, and how they risk areas
will build on the strengths. Add these aspects Therefore we suggest adopting an
Colored oval approach based on the concept of
to the map of strengths and weaknesses on cards and
oval cards (to differentiate them from square/ the “thinking hats” to facilitate the
pens for each discussion of the guiding questions
rectangular used previously). Based on this participant
assessment, ask them to select the five most (School of Thinking, 1983). This
promising measures. method encourages participants
to collectively look at the guiding
questions from different angles. This
5.3. Participants place the color cards with approach stimulates dialogue and
the selected measures in the WSI Model blocks debate, as all participants have
15 where they have the first direct effect. Ask WSI Model pin to adopt the same way of thinking (they
min. participants to visualize the expected effects board wear the same hat) — for example, by
of the key activities throughout the WSI Model giving only positive remarks about a
using oval or round cards, for example. guiding question in the first round. In
the next round, everyone then changes
their attitude (hat) to give only negative
remarks. This implies doing away with
the famous phrase “yes but ...,” which
is a root cause of unproductive debate.
Have a jointly established action plan and timeline for the implementation of the most relevant key activities.
Understand the link between the key activities and the operating principles.
time activity materials
Color cards and
30 6.1. Let the group discuss how they want to implement each of the selected
pens for each
min. measures, and if or how they want to use any of the supporting tools.
participant
6.2. Ask the group to identify implementation steps4 and write them on color cards.
Ask participants to agree on dates for the implementation of each step and the
Pin board with
timeframe and responsibilities5 for overall activities. For resource-intensive or
planning matrix
otherwise complicated activities, participants should mark options where they need
60 to seek support. Pin board with
min. map of strengths
Refer the participants back to the analysis of how the selected activities relate to the
and weaknesses
strengths and weaknesses (Exercise 5) and ask them what aspects need to be taken
as reference
into account during their implementation. Add these as “remarks” in the planning
matrix.
Optional exercise: For a WSI that is entering the renewal phase, it may be Life cycle
20
beneficial to map activities against the life cycle and identify which activities are time presentation and
min.
sensitive and which could be postponed. pin board
6.3. To clarify the link between key activities and the integrity of a WSI, participants
should link the effects of each key activity (Exercise 5) to the operating principles.
Ask the participants to add the anticipated effects of the activities to the timeline and Color cards
30
highlight which operating principle(s) these contribute to. with operating
min.
principles
If working with a large group, this can be done in smaller groups, each focusing on
one activity and sharing afterwards.
Follow up
After having attended the management workshop or completing individual exercises, participants need to
implement the measures chosen. The implementation phase is the longest and most difficult step of the whole
integrity risk management process. Depending on the complexity of the measures, this phase can take anything
from six months to a year (or even longer). It is very important to create ownership and leadership to ensure that
the implementation process is successful. It is therefore important that responsibilities for each measure have
been clearly assigned and that a focal person (e.g., the WSI manager, coordinator, or another WSI participant)
for the integrity risk management process is established.
An integrity risk management focal person shall lead the implementation process along the road map that
has been jointly developed by the WSI participants in Exercise 6. In doing so the focal person should identify
support needs among WSI participants who are responsible for the implementation of key activities. The focal
person should further communicate with those responsible for the implementation of activities to regularly
agree on the next implementation steps and communicate outcomes to other WSI participants.
Unexpected difficulties can arise, and resistance from different levels may affect progress and the overall
implementation of key activities. A sound understanding of why activities were completed, and why certain
milestones were not met, is crucial for a successful integrity risk management process. The focal person should
therefore receive adequate support (for example, from the neutral WSI facilitator or from an external coach) to
reflect on the implementation process. Note that the primary objective of the support function is not to control
the focal person but rather to ensure a successful process that leads to integrity assurance for the WSI.
56 August 2015
Overview of facilitation materials
A set of facilitation materials is provided to support the implementation of an integrity management
workshop for WSIs. These materials are available upon request from the Water Integrity Network, the CEO
Water Mandate, and GIZ, and include:
▨▨ Integrity risk areas on the front and related guiding questions on the back
▨▨ Guiding questions on the front and related instruments on the back
▨▨ Operating principles
Further Reading:
- Janek Hermann-Friede, Michael Kropac, Sarah Achermann, Johannes Heeb, and Lotte Feuerstein.
2014. Integrity Management Toolbox for Water Service Providers — Manual for Facilitators (Berlin: cewas, WIN,
and GIZ). http://www.waterintegritynetwork.net/publications/.
- Alex Osterwalder and Yves Pigneur. 2009. Business Model Generation: A Handbook for Visionaries,
Game Changers, and Challengers (Osterwalder & Pigneur, ISBN 978-2-8399-0580-0). http://www.
businessmodelgeneration.com (2010. Wiley, ISBN-10: 0470876417).
- Jan-Teun Visscher and Janek Hermann-Friede. 2011. AWIS Facilitator’s Guide (Berlin: WIN and
Transparency International). http://www.waterintegritynetwork.net/publications/.
7 We suggest using 3 x 5 ft (116 x 140 cm) brown papers to provide sufficiently large workspace for participatory exercises. If available,
using a sticky cloth (nylon cloth with repositionable spray adhesive) is an effective alternative to visualize results.
8 Peter Newborne and Nathaniel Mason, “The Private Sector’s Contribution to Water
Management: Re-examining corporate purposes and company roles,” Water Alternatives 5
(2012): 603–618.
58 August 2015
To identify capture risks, practitioners need to examine how their WSIs could be misused as a platform to
mislead representatives of public institutions or divert the attention of public officials in favor of vested
interests instead of acting in the public interest. A review of the potential red flags listed in Table 4 suggests
that most WSIs pose structural risks of capture. This is not to infer that these WSIs should not be pursued,
but instead that all participants should be clear about capture risks and that locally appropriate strategies to
counter policy capture need to be prioritized. Avoiding policy capture requires proactive strategies and on-
going management. Because of the wide diversity and complexity of capture risks, mitigation is a nonstandard
task and requires an interpretive, context-specific response.
▨▨ Individual WSI participants and affected stakeholders can use the red flags as an orientation
to scan an initiative for capture risks.
▨▨ The red flags can be discussed pro-actively within a WSI to raise awareness of capture risks and
to engage in a dialogue on what constitutes capture in a given WSI and how it can be
mitigated.
▨▨ The red flags can be used to thoroughly assess capture risks as part of an integrity risk assessment (see
Tool 1a) or a wider risk management effort.
To address the subjective nature of capture risks, a collective analysis by a balanced group of stakeholders
increases the reliability of the results. Information from a detailed context analysis (see Tool 5) can provide
additional information to evaluate capture risks.
The four steps laid out below provide an outline for a participatory approach to address capture risks in a WSI.
Public resource capture occurs where public resources — whether WSIs that:
civil servant staff time, political or organizational attention, or
▨▨ Deplete the time, energy, and resources
departmental budgets — are diverted to serve a narrow group of
of an overstretched public agency (or
interests at the expense of the wider societal or public interest.
civil society group) to address an issue of
For example, concerns voiced by powerful WSIs about potential primarily private interest that has little
Public public infrastructure investments with limited public benefit may consequence for the wider public
resource divert limited budgets away from pre-existing priorities such as ▨▨ Result in government expenditure or local
capture the less visible water access, sanitation, and hygiene (WASH) budgets
needs of the poorest communities. Public resource capture would
also prevail where a WSI negotiates the disproportionate use of ▨▨ Concern investment, development,
public funds to deal with the externalities or costs associated with and/or operation and maintenance of
water use by a private interest (e.g., in negotiating investment in infrastructure
the treatment of private wastewater, contaminated land, or mine ▨▨ Involve or directly influence the workload
water). of senior or mid-level civil servants.
60 August 2015
In WSIs whose:
Process capture concerns the undue influence or control of certain
interests in deciding and designing “how things are done” with the ▨▨ Engagement is by invitation only or involves
end result that outcomes are skewed and distorted toward the an element of “pay-to-play” or pre-
needs or perspectives of narrow particular or private interests selection in membership
versus wider public interest. ▨▨ Governance group is self-selecting
Process capture is about how things are done, the questions and unbalanced in representation or
Process
asked, who is in the room, how decisions are made, and the degree perspectives
capture
of control handed to those who are funding the initiative: “He who ▨▨ Stakeholder participation in developing the
pays the piper calls the tune.” Process capture can also stem from WSI, framing the issues, decision-making,
sheer contrasts in stakeholders’ capacities to negotiate WSI rules stakeholder composition, and process
and effectively participate in WSI processes, and thus depends on design is weak
the extent to which the WSI strives to build such capacities in all
▨▨ Financing is dominated by individuals or a
participants (e.g., partners’ representatives) from the onset.
small number of interest groups.
WSIs that:
Narrative or ideational capture refers to the subtle power exerted
through influence on the way things are portrayed or described ▨▨ Finance or develop research and
and the development of concepts, theories, and ways of looking at conceptual development
the world. ▨▨ Involve “awareness raising,” training,
capacity building, and outreach
Narrative or For example the “shared risk” narrative around WSIs plays down
ideational the disparities in vulnerability, power, and access among water- ▨▨ Promote potentially inappropriate or
capture using interests. Narratives around water pricing and allocating controversial approaches to water
water toward the highest monetized value uses is a further governance such as offsetting or net
example of ideational power that can result in legitimizing or impact, water trading, pricing, charging
advancing private interests ahead of the public interest, because and allocation reform, water funds, large-
it is difficult to assign a monetary value to cultural, social, and scale rainwater harvesting or groundwater
environmental values. recharge, large-scale infrastructure, and
payment for ecosystem services.
The “brain drain” is where the most qualified and capable local,
national, or regional practitioners and staff are employed or
seconded into NGOs, donors, and corporations engaged in WSIs
in duties peripheral to water management, rather than into water
management agencies in government, because of better pay and WSIs that:
conditions or allowances.
▨▨ Employ or second staff and experts from
Human resource capture also involves the creation of loyalties and the public sector
Human privileged relationships between private interests and government
resource ▨▨ Provide attractive professional
staff by offering professional opportunities, secondments,
capture opportunities such as training and overseas
training, and other inducements. The payment of per diems and
missions
other allowances is an example that erodes the independence
and neutrality of civil servants. One of the greatest limiting ▨▨ Pay participants allowances and
factors for good water governance and sustainable water inducements for their involvement.
management is the availability of suitably experienced and
motivated personnel. Although involving government staff in WSIs
can help build capacity, human resource capture is a primary
concern relating to WSIs.
The most basic form of capture involves acquisition of additional or
privileged access to the water resource itself. As a result of other
forms of capture, there is a risk that private interests negotiate or
seize water resource access and use, undermining the ability of WSIs focusing on:
other users — the public or the environment — to meet their own
needs, particularly in times of shortage, conflict, or drought. ▨▨ Investment, development, operation, and
Water maintenance of infrastructure
resource A good example may result from private investment in public
capture ▨▨ Water offsetting, compensation, net impact,
water infrastructure based on conditional agreements around the
Payment for Ecosystem Services;
continuation of supply during times of drought. Another example
may be the long-term establishment of offsetting provisions in law ▨▨ Water use planning and allocation regimes.
that effectively allow water access to be bought by those able to
pay, thereby undermining the principle of water allocation based
on greatest public benefit.
1. Participatory and inclusive WSI initiation, development, and integrity risk assessment processes that include the
full range of stakeholder interests with adequately diverse perspectives and experience to identify potential risks.
2. A carefully developed and clearly articulated development path or theory of change for the WSI that
transparently sets out its intended impacts, outcomes, outputs, and roles of WSI participants, against which
progress is publicly tracked and communicated.
3. Diverse representation at a governance and senior decision-making level of WSIs and avoidance of stakeholder
engagement that is either selective or discretionary, or that requires payment or significant resources to
participate.
4. Cognizance of and adherence to mutually agreed public and private roles within the initiative.
5. Sufficient strategic alignment so that public sector involvement in the WSI is derived from public funds and pre-
existing budgets rather than sourced by the private or NGO sectors.
6. Clearly benchmarked and communicated policies for remuneration or payments of costs and allowance, with the
latter based on reimbursement of real and receipted expenditure.
7. Independent oversight or scrutiny of the WSI by a credible and legitimate organization or body.
3. Independent and untied funding sources for civil society and academic engagement in water stewardship, and
investment in social accountability monitoring.
4. Strengthening the separation of powers and checks and balances among judiciary, executive, and legislature and
the oversight role of parliamentary committees.
5. Human resourcing strategies within donor, NGO, and private sector actors in developing countries that recognize
and respond to the hazards of draining public sector expertise.
6. Nurturing professional retention and workplace motivation through new forms of capacity building.
Further reading:
- CEO Water Mandate. November 2010. Guide to Responsible Business Engagement with Water Policy. http://
ceowatermandate.org/files/Guide_Responsible_Business_Engagement_Water_Policy.pdf.
- Integrity Vice Presidency. (no date). Fraud and Corruption Awareness Handbook — How it works and what to
look for: A handbook for staff. Washington DC: The World Bank Group. http://siteresources.worldbank.
org/INTDOII/Resources/INT_inside_fraud_text_090909.pdf.
62 August 2015
Tool 2: WSI Model — A Template to Describe the Logic of WSIs
WSI facilitators and core participants usually agree at an early stage on There were no clear objectives
the cornerstones of how a WSI will operate and generate shared benefits. for us, no clear benefits
Nonetheless, the written agreements often take time to develop and use so it was difficult to see
what we were aiming for.
legal language that is not easily understood by all WSI participants. This
—[Private Sector]
leaves room for contradicting interpretations and expectations among
WSI participants and beneficiaries, which can result in conflicts and
undermine the accountability relationships among different stakeholders
These problems are really
both within and outside the WSI. The WSI Model (Sample model is
about accountability and how
provided at the end of this tool) provides a structure through which WSI the project should identify
participants can discuss and agree on key aspects of the WSI in simple issues and target at the design
terms, establishing a shared understanding among all participants. Doing phase. Where is the theory of
so helps create transparency and provides key information for an analysis change?
of the most salient integrity risks the WSI may face. Beyond this, the WSI — [Civil Society]
Model helps to clarify the theory of change along nine building blocks:
1. Participants
2. Activities (Testimony from field
3. Governance structures assessments)
4. Commitments and contributions
5. Goals and objectives
6. Mechanisms for engaging affected stakeholders
7. Affected stakeholders
8. Local water challenges and priorities
9. Benefits
Further reading:
- Alex Osterwalder and Yves Pigneur. 2009. Business Model Generation: A Handbook for Visionaries,
Game Changers, and Challengers (Osterwalder & Pigneur, ISBN 978-2-8399-0580-0). http://www.
businessmodelgeneration.com. (Also: 2010. Wiley, ISBN-10: 0470876417).
64 August 2015
Internal to the WSI LINK to the environment
and context of the WSI
What internal governance accountability structures What local water challenges exist in the basin? What
exist for the initiative, and how effective are they? are the local policy priorities for the region?
There is no community Effective WSIs need a wide range of stakeholders — both the influential
representation ... that is and the affected — to be engaged in appropriate ways. Identifying relevant
the wrong approach and
stakeholders and understanding their perspectives and interests is
we need to change … to sit,
plan, decide, and act with known as stakeholder mapping. Without proper stakeholder mapping, the
communities to avoid conflict. WSI may be unable to identify the wide variety of interests and concerns
[Public Sector] that exist in a particular context, potentially leading to an initiative that
serves the more dominant and powerful to the detriment of others. Good
stakeholder mapping helps mitigate integrity risks through:
The weakness was that
Identifying affected stakeholders so that they can be directly involved
there was no government
involvement and no and better understood. This helps ensure that their legitimate interests
information from them. This and knowledge are taken into consideration.
lack of wider involvement
affects the validity and - Identifying relatively more dominant and less powerful or poorly
impact. [Private Sector]
represented interests to balance power relations, representation,
and perspectives.
(Testimony from Field - Identifying the full range of interests in order to broaden the
Assessments) number and diversity of groups and individuals engaged in
achieving the WSI objectives.
66 August 2015
Guidance for implementation
The steps laid out below highlight what WSI initiators and participants need to do in order to successfully
complete a stakeholder mapping exercise.
Type of
Key questions
analysis
Which external parties have a direct influence over, or are required to participate in, any
Decision point
decisions that will be needed to address your water-related challenges?
Which external parties are in a position to directly or indirectly support addressing your water-
Opportunity
related challenges?
Which external parties can contribute knowledge and advice to improve problem
Expertise
characterization, or expand or refine the understanding of solutions?
Which external parties will experience benefits (or costs) associated with addressing your
Impacts
identified water-related challenges?
Which external parties have an interest in the collective action process or its outcomes, even if
Expectations they might not otherwise have a specific role to play in problem solving or a connection to the
distribution of costs and benefits?
Which external parties currently (or will potentially) experience conflicts with you or other
Conflict potential parties in the process in a manner that may influence the available options to
address your identified water-related challenges?
- AccountAbility. January 2011. “AA1000 Stakeholder engagement Standard 2011 (AA1000SES).” www.
accountability.org.uk.
- WIN and cewas. 2014. Integrity Management Toolbox for Water Sector SME — Manual for Coaches. Berlin: Water
Integrity Network and cewas (International Centre for Water Management Services). http://www.sswm.
info/sites/default/files/reference_attachments/Manual%20IM%20Toolbox%20SME.pdf
- CEO Water Mandate. September 2013. Guide to Water-Related Collective Action. http://ceowatermandate.org/wp-
content/uploads/2013/09/guide-to-water-related-ca-web-091213.pdf.
- Mark S. Reed, Anil Graves, Norman Dandy, et al. 2009. “Who’s in and why? A typology of stakeholder analysis
methods for natural resource management,” Journal of Environmental Management, 90(5): 1933–1949.
9 These analyses were drawn from the CEO Water Mandate’s Guide to Water Related Collective Action (2013). Although they were
initially designed to gauge whether external parties might add value as additional WSI participants, they can also be used to better
understand the relevance of WSI stakeholders.
68 August 2015
Tool 4: Due Diligence Investigation of WSI Participants
Due diligence refers to the care a reasonable and prudent party should There is intentional damage
take before entering into an agreement or transaction with another par- and neglect of the water
ty — whether they are NGOs, government, or private companies. It in- infrastructure by the
volves a systematic collection and analysis of information on how a par- municipality staff. [Donor/ESA]
ticular organization is managed or conducts its business. A due diligence XXX is distancing themselves
investigation reveals whether a potential participant in a WSI commits from the partnership when it’s
to professional and ethical business practices, and uncovers the risks and not bringing immediate benefit.
opportunities that come along with involving this participant. A due dil- [Civil Society]
igence assessment will be useful for the WSI initiators while scoping (From Field Testimony)
prospective participants in order to assess whether that organization is
fit to assume a specific role in the WSI.
Level of Effort:
Simple investigation: Applied to all potential participants
In-depth investigation:
- To be used following the outcome of a simple due diligence that
highlights potential areas of conflict
- To be used if a WSI is intended to address sensitive areas (such as
regulations)
- To be used if a potential participant will play a key role (e.g., WSI
facilitator).
70 August 2015
Guidance for implementation
To streamline data collection processes, the due diligence investigation can be linked
to the stakeholder mapping exercise and context and political economy analyses that
should be carried out at the outset of a WSI.
Step 1: Define
Methodology and Data Investigation should include different sources of information (see box on potential data
Sources sources).
If methodology for participants consists of a reduced/simplifed checklist, thresholds
should be defined for deeper investigation.
WSI initiators select who will conduct the investigation based upon the goals,
objectives, and potential-make-up of the WSI. Question to ask include, “Who is best
positioned to carry out the due diligence? Would an external party be helpful to work
through potential conflicts of interest?
Options for how to conduct such an investigation includes a local consultant; external
Step 2: Conduct Initial independent organization or individual according to terms of reference (TOR, see
Investigation Tool 5, Step 1); key members of the WSI who utilize a simple checklist of verified
information.
Table 8 provides guidance on questions that should be explored during the
investigation.
Where a WSI might be operating in a high-risk context, WSI initiators might consider
conducting further background checks with local experts to verify outcomes.
Discuss initial findings among WSI initiators resulting in a joint decision about who to
invite to participate in the WSI.
Where the investigation finds critical issues, WSI initiators may choose to hold a
bilateral meeting with the individual/organization to assess whether and how the
identified problems or sensitive issues might be addressed.
Exclusion of potential participants should be based on an in-depth investigation.
Step 3: Reach In circumstances where a number of sensitive or controversial issues might arise, an
and Document efficient and constructive way to collate and weigh due diligence information gathered
Conclusions in Step 2 is likely a meeting or worskhop setting.
In the workshop, potential WSI participants introduce their organizations, and findings
of the intial investigation are presented.
The workshop format allows the group to discuss and come to consensus about any
controversial issues.
Intelligent workshop design and facilitation will be necessary to handle sensitive
issues.
Continued due diligence reporting and monitoring should be carried out to adapt to
new issues as they emerge.
Step 4: Follow Up In particular, a conflict of interest register should be kept up to date and should be
acted upon. The results of due diligence can also be made public to increase the
credibility and legitimacy of the WSI.
Find out more about participant status, purpose, and governance. Consider checking:
▨▨ Governance documents (articles of incorporation, bylaws, NGO registration)
▨▨ Annual reports, brochures, etc.
▨▨ Ownership structure (who is behind the institution?)
▨▨ Curriculum vitae of trustees or directors and senior staff
Background
information ▨▨ Board of Trustees/Directors meeting minutes
▨▨ Political affiliations
▨▨ Previous or pending legal cases, fraud, or accusations of improper conduct or corrupt
practice
What is the legal status of the organization? What is its core purpose? To whom is it
accountable, who is it of use to, and who does it actually represent?
Does the organization have policies relating to the following areas? Are they adequate, and
are they followed? How is this demonstrated?
▨▨ Protection of children and vulnerable people
▨▨ Anti-corruption, including whistle-blowing safeguards
72 August 2015
Consider checking the sustainability and financial viability of the participant:
▨▨ Most recent annual reports, financial statements, and regulatory reports (audited, if
Financial position available)
▨▨ Budget for upcoming financial year and current and projected income forecasts
▨▨ Finance manual and expenditure procedures
Will the organization be able to deliver on agreements and roles set out in the WSI?
Consider checking:
▨▨ Organizational structure chart
Why is the organization relevant to the WSI? What is its rationale for engagement?
▨▨ What are the benefits sought by the organization through its involvement with the WSI?
Are they in line or can be aligned with sustainable water management?
Intent and ▨▨ How will those benefits be measured and tracked?
incentives
▨▨ Are there any other potential benefits or stakes at risk that motivate the organization’s
involvement?
▨▨ Are there any conflicts of interest (such as positioning for contracts, access to decision
makers), and how will they be managed?
Further reading:
- Partnering Against Corruption Initiative (PACI). 2013. “Good Practice Guidelines on Conducting Third-
Party Due Diligence.” (Geneva: World Economic Forum). http://www3.weforum.org/docs/WEF_PACI_Co
nductingThirdPartyDueDiligence_Guidelines_2013.pdf. N.B.: Contains sample questionnaires for due
diligence assessments that can be adapted.
- Guide to Combating Corruption and Fraud in Development Projects. 2014. http://guide.iacrc.org/local-
and-on-site-due-diligence-checks/.
- For information on filing requirements, see World Bank Group (2014), “Starting a Business,” http://www.
doingbusiness.org/data/exploretopics/starting-a-business.
- Matteson Ellis. February 4, 2014. “The Master List of Third Party Corruption Red Flags,” FCPAméricas Blog,
http://fcpamericas.com/english/anti-corruption-compliance/master-list-party-corruption-red-flags/#.
- PInow. (no date). “Due Diligence Investigations.” http://www.pinow.com/investigations/due-diligence.
74 August 2015
ter program implementation, or catchment governance. These issues are, in Context Analysis — Key Tips:
turn, influenced by an intricate set of drivers and trends in the wider envi- ▨▨ Do not wait too long to do
ronment that may be beyond the control of WSI participants, but that need the analysis, as it provides
to be understood in order to achieve the WSI’s intended benefits. key insights for planning.
▨▨ Use credible and well-
The context analysis focuses on the multiple dimensions of external forces: respected experts whenever
environmental, technological, socio-economic and cultural, market, policy needed.
(both institutional and regulatory), and political factors. Findings provide ▨▨ Ensure that findings are
the basis for designing the scope, structure, management, work program, neutral and objective.
and the monitoring and evaluation framework of the WSI. Developing a WSI ▨▨ Conduct the analysis as a
participatory process from
with insufficient understanding of its context could result in WSI partic-
procurement to validation of
ipants working on the wrong issues, in the wrong places, with the wrong results.
people, and in the wrong ways. A context analysis can help identify needed ▨▨ Use current trends and
action, flag potential integrity risks, and prompt solutions to mitigate them prospective findings to
before they arise. strengthen the rationale for
the WSI.
The context analysis should ideally start during the incubation phase of the ▨▨ Be sure to understand the
WSI to provide a baseline understanding of the surrounding conditions, and political economy, which
continue through the end of the first phase and into the formalization phase concerns why things
happen and how they can be
as the WSI matures and objectives and goals are set. As contextual factors influenced.
change, key findings and assumptions should be reviewed from time to time
▨▨ Revisit the analysis regularly.
so that the WSI can be adapted accordingly.
WSI initiators (or a core group of participants) develop an impartial ToR for the context
analysis that includes the methodology (highlighting a participatory approach), outputs, and
expert profile via a joint exercise to mitigate against bias (or perceptions of bias).
Step 1: Develop
The methodology can build upon existing analyses such as political economy analysis or
Terms of Reference
water risk assessments. Might combine desk study with field observations and input from
(ToR)
WSI stakeholders.
Sample questions provided in Table 8 can be adapted to the local context and used in
conjunction with the ToR.
Work is carried out typically by a suitably qualified researcher or consultant (or a small team)
Step 2: Select contracted by the WSI.
Expert(s) to Conduct
the Analysis An expert with local knowledge and credibility will increase the likelihood that the analysis is
well received by WSI participants and the chances that it will inform an accepted strategy.
Use a participatory approach to the context analsyis. Though it might sound time consuming,
it leads to a high-impact and high-integrity effort.
A participatory approach leads to a rich understanding based on robust quantitate and
qualitative data, inputs from stakeholders, and a balanced synthesis of their perspectives.
Participation should be built into the ToR (Step 1 above), in data collection, analysis, and
Step 3: Tap into the
validation.
Knowledge of WSI
Stakeholders Findings should be shared with WSI participants and external stakeholders in an accessible
manner with time allocated to gather and integrate their feedback and respond to their
concerns (e.g., through feedback workshops with separate stakeholder groups and or during
WSI meetings).
Stakeholder validation is vital to build a strong foundation of shared understanding and
reliable knowledge (see Figure 5).
Desk-based research:
Field observations:
Review of documents, studies,
of environmental and social
and primary and secondary
interactions
data
StakeHolder
Validation
Stakeholder testimony:
Interviews and/or surveys of partners and beneficiaries,
focus group discussions, and group meetings
The context analysis needs to make use of a holistic analytical framework. Besides describing the state of
affairs, current dynamics and trends, it should develop scenarios to strengthen the rationale for the WSI and
further sharpen strategic orientations.
The STEEP (social, technological, economic, environmental, and political) framework, used worldwide by
companies in strategic analysis and market research to gain an overview of the different macro-environmental
factors, provides a useful template. Table 8 adapts this framework to the relevant dimensions of water
stewardship.
Table 8 is a compilation of potentially relevant questions that has been prioritized within each example. WSI
participants will need to adapt and prioritize questions according to the nature and scope of their initiative,
as well as the status of existing context information.
76 August 2015
Table 8: Suggested Dimensions and Questions to Help Guide a WSI Context Analysis
Environmental or river basin context
Priority:
▨▨ Does reliable data and information on water availability and quality exist? What does it cover, and is it
accessible?
▨▨ To what extent have there been water stress or supply shortages in the river basin or watershed? Are the
legitimate and basic water needs of other stakeholders (including the environment) affected negatively because
of large-scale water users (e.g., abstraction, pollution, by companies and their partners in the supply chain)?
▨▨ Have there been any water-related conflicts? If so, who was involved and what were the conflicts about?
▨▨ Which ecological factors affect the successful implementation of Integrated Water Resources Management
(IWRM)?
Further questions:
▨▨ To what extent does increased climate variability alter underlying water resources and make existing supply
arrangements and infrastructure inadequate to meet existing or anticipated demands? How does climate change
influence local, national, or regional (or trans-boundary) debates on the need to address shared water risks?
Priority:
▨▨ To what extent do demographic patterns (e.g., population growth, changes in preferences for living
arrangements, household consumption) affect: (1) the demand for water access, sanitation, and hygiene (WASH)
services, (2) the competition among water users, (3) the locations where water infrastructure can be built or
operated, and (4) the consumer base available to support infrastructure development and maintenance?
▨▨ How does economic development activity in the catchment (e.g., industrial, commercial, agricultural) affect
demands on existing water resources? What impact does this have on water quality and the ecosystem?
▨▨ How do other socio-economic factors (e.g., social cohesion, poverty and livelihood considerations, cultural
attitudes, gender, and values) influence the relationships with service providers, the role of the community in the
management of WASH services, stakeholder engagement, security, etc.? Are there local social structures
that the WSI can build on to enhance its effectiveness and reach?
Further questions:
▨▨ To what degree are social norms and expectations at country and catchment levels evolving with regard to water
quality and accessibility, and to the maintenance of ecosystems and species?
Market context
Priority:
▨▨ Who makes what decisions with regard to economic priorities and public investments that may be relevant to
the WSI? Who are the dominant actors within the market, and who gets sidelined? (See Tool 3, Stakeholder
Mapping).
▨▨ Are policies and regulations that govern the goals of the local economy consistent with those around protecting
and allocating water resources?
▨▨ How is the local economy evolving? What are the likely influences on water use by producers of goods, or shifts
in resulting use of those goods by consumers?
▨▨ How do new entrants gain access to licenses (e.g., for water abstraction, effluent discharge, solid waste
collection)?
Further questions:
▨▨ What is the scope for small-scale financing or credit to WASH providers?
▨▨ Have there been payments made for environmental services (e.g. taxes or fees)? What does the future look like?
78 August 2015
Political context
Priority:
▨▨ How do formal and informal decision-making processes at local government and community levels work? Who
are the key players, and how representative are they?
▨▨ What are the prevailing attitudes and interests within each major stakeholder group toward the problem
addressed by the WSI and the envisioned activities or approaches? (See Tool 3, Stakeholder mapping.)
▨▨ What are the prevailing attitudes within each major stakeholder group toward multi-stakeholder partnerships?
▨▨ What are the prevailing attitudes within each major stakeholder group toward transparency and practice in terms of
codes of conduct?
Further questions:
▨▨ How much space already exists for advocacy and networking around the issues tackled by the WSI?
▨▨ To what extent can the WSI be affected by the political cycle, a change in power structures, or individuals in
power? How much could a shift in government or stakeholder priorities influence the involvement of different
WSI participants?
Priority:
▨▨ What is the current relationship between the public, private, and civil society sectors (e.g., adversarial,
unconnected, supportive, mainly based on philanthropy or CSR)?
▨▨ What are the attitudes of the different stakeholder groups toward each other?
▨▨ What has been the experience of WSIs or IWRM-related multi-stakeholder partnerships in the country and in
the area? What kinds of roles have these partnerships played to date (e.g., regulatory/policy, investment and
finance, implementation, technology innovation, social accountability innovations, other)?
▨▨ What level of engagement have they achieved (i.e., informative, consultative, collaborative, integrative)? Can
higher levels of engagement be envisioned?
▨▨ Are they generally successful? Sufficiently “partnership oriented”?
Further questions:
▨▨ Are there examples of multi-stakeholder partnerships operating outside the IWRM sector (WASH, energy,
health, education, etc.)? If so, how successful have these been (or been perceived to be), and do they provide any
lessons for the WSI?
▨▨ For examples found, how vested are the different stakeholders in the partnership? What is the nature of and
commitment to their contribution (e.g., merely a funding channel for NGO projects, a lobbying mechanism for the
private sector)?
▨▨ For examples found, what is the national, regional, and local interaction within these partnerships? How does
(de)centralization shape these relationships?
▨▨ What other kinds of relationships of a formal nature (public-private contracts, public-NGO service delivery
contracts, etc.) exist among the different stakeholder groups?
▨▨ What kinds of relationships beyond standard contracts (e.g., for regulating, advocacy, innovation funds, policy
platforms, etc.) exist among sectors? Are external donors supporting such efforts? If so, how?
▨▨ What are public sector incentives to and attitudes toward convening, leading on, and engaging in multi-
stakeholder partnerships? Do officials have the required capacities and skills across different levels of
jurisdiction (center, provincial, district, etc.)?
▨▨ What traditional roles have civil society organizations played in multi-stakeholder partnerships? What might
further support their engagement in or strengthen their role in a WSI?
Further reading:
On the process and methods of context analysis:
- Ken Caplan and Robin Farrington. (forthcoming). Emerging Lessons from the Water Futures
Partnership: Collective Action Guide Part 2.
- CEO Water Mandate. September 2013. Guide to Water-Related Collective Action. http://
ceowatermandate.org/wp-content/uploads/2013/09/guide-to-water-related-ca-web-091213.pdf.
- Alan Thomas, Joanna Chataway, and Marc Wuyts, eds. 1998. Finding Out Fast: Investigative Skills
for Policy and Development, pp. 307–332. (London, Thousand Oaks, New Delhi: Sage).
- Department for International Development (DFID). July 2009. “Political economy Analysis —
How to Note: A DFID Practice Paper.” London. http://www.odi.org.uk/events/2009/07/23/1929-
dfid-note-political-economy-analysis.pdf.
- United Nations Development Programme (UNDP). 2012. “Institutional and Context Analysis
Guidance Note.” (New York: UNDP). http://www.undp.org/content/undp/en/home/librarypage.
html.
Analytical frameworks for context analysis:
- GIZ. 2009. “Capacity Works.” (Eschborn: Deutsche Gesellschaft für Internationale
Zusammenarbeit (GIZ) GmbH). http://www.giz.de/expertise/html/4619.html
- Joy Moncrieffe and Cecilia Luttrell. 2005. “An Analytical Framework for Understanding the
Political economy of Sectors and Policy Arenas.” Overseas Development Institute (ODI).
http://www.odi.org/sites/odi.org.uk/files/odi-assets/publications-opinion-files/3898.pdf.
On alignment of WSI with water governance structures:
- European Commission. 2011. Water Project Toolkit, p. 98 on. (Luxembourg: EU Publications
Office). www.aquaknow.net.watertoolkit.
80 August 2015
Tool 6: Support Materials for a Participatory Planning Process
Note: Given the importance of participatory planning processes to the impact and integrity of
WSIs, the project sponsors and partners are developing further WSI-specific guidance and tools
that will be available online in due course.
A broad overview of the importance of participatory planning processes to the integrity of WSIs,
Tool
introduction to key principles and commonly used approaches, and useful reference material.
Related Key
Define scope, objectives, and public interest benefits of the WSI.
Activity
Build legitimacy and credibility, and avoid conflicts and capture through balanced stakeholder
engagement:
Purpose
Identify interests and needs of affected stakeholders to inform the planning process.
Expand the knowledge and resources that inform WSI development and implementation.
Possible
WSI facilitators, managers, and coordinators.
Users
Level of
Inherent to the facilitation and management of WSIs.
Effort
Effective stakeholder engagement is key to ensuring the needs, knowledge, perspectives, and interests of
those impacted by the WSI are represented. Poor stakeholder engagement can negatively impact WSIs in
several ways: among other things, it can lead to inappropriate or uninformed design, undermine durable
outcomes, and contribute to stakeholder conflict. Further, where affected stakeholders are not involved
adequately, WSIs cannot be assured to act in the public interest, and the lack of gatekeeping may increase
capture risks.
Conversely, the active involvement of stakeholders provides important knowledge about the WSI context,
which is required to mitigate integrity risks. Good participatory processes pass a sense of ownership to
those involved (or affected), and thereby establish the credibility and legitimacy of the WSI and contribute
to sustainability and transparency. In addition, proper stakeholder engagement ensures that affected
stakeholders are adequately informed about the initiative, its progress, and possible obstacles, which
constitutes the basis for accountability of WSIs.
Those affected by the WSI and those influential to its successful outcome will need to be represented and
engaged in appropriate ways. Part One–Section IV Applying the WSI Integrity Principles in Practice provides
an indication of minimum requirements for stakeholder engagement. To further support WSI managers
and facilitators with additional guidance around possible forms of communication and approaches for
engagement, this section introduces selected publications that may be helpful in designing a WSI-specific
stakeholder engagement strategy.
The CEO Water Mandate’s Guide to Water-Related Collective Action (2013)10 targets private sector stakeholders
with an interest in corporate water stewardship. The document provides guidance on preparing for a
collective action (e.g., what needs to be clarified and researched), as well as principles and structural elements
for managing collective action, which can inform a WSI’s stakeholder engagement strategy. For example,
the document provides an overview of categories of potentially interested parties (p. 19) that can be used as a
starting point for the stakeholder mapping process.
Advantages Adaptation
▨▨ Guidance for stakeholder engagement specified ▨▨ Needs to be partly adapted for communication with
to the conditions of WSIs types of stakeholders other than the private sector
▨▨ Case examples and lessons learned are ▨▨ Specific interventions need to be established based
documented as a practical reference on generic guidance and case examples
The International Council on Mining & Metals11 has provided a practical guidance to identify stakeholders,
clarify their concerns and aspirations, delineate engagement objectives, and initiate iterative consultation,
as well as to communicate intentions, evaluate progress, and maintain engagement. Although the document
is not solely focused on the more formalized WSIs that are the subject of these guidelines, the guidance for
stakeholder engagement provides practical steps relevant to participatory planning processes.
The AA1000 Stakeholder engagement Standard (AccountAbility 2011)12 provides advice on: (1) how to
establish the necessary commitment to stakeholder engagement, and how to ensure it is fully integrated
in strategy and operations; (2) how to define the purpose, scope, and stakeholders of the engagement;
and (3) what a quality stakeholder engagement process looks like. The AA1000 Standard supports the
implementation of criteria for quality stakeholder engagement by organizations, which equally apply to
WSIs.
10 CEO Water Mandate, Guide to Water-Related Collective Action (September 2013), http://ceowatermandate.org/wp-content/
uploads/2013/09/guide-to-water-related-ca-web-091213.pdf.
11 International Council on Mining and Metals (ICMM), “A Practical Guide to Catchment-Based Water Management for the Mining and
Metal Industry” (2015), www.icmm.com/document/8329.
12 AccountAbility, “AA1000 Stakeholder engagement Standard 2011 (AA1000SES)” (January 2011), www.accountability.org.uk.
82 August 2015
Advantages Adaptation needs
▨▨ Comprehensive, practical guidance for the ▨▨ Needs to be adapted from a primary focus
design of stakeholder engagement strategies on individual organization’s efforts to engage
that contribute to enhance accountability of stakeholders to the context of WSIs
organizations and initiatives ▨▨ Specific requirements are needed to ensure
▨▨ Helpful, process-oriented elaboration of what stakeholder engagement contributes to the SWM
constitutes good stakeholder engagement needed (e.g., building on existing sector institutions)
Over recent decades, participatory approaches to forestry have been evolving in many parts of the world. The
participatory and multi-stakeholder aspects of national forest programs have similar challenges as water-
related collective action because stakeholders often have competing interests regarding both water and
forest resources. The National Forest Programme and the Food and Agricultural Organisation of the United
Nations (O’Hara 2009)13 provide guidance on relevant tools and methodologies for stakeholder engagement
processes, as well as a training manual on enhancing stakeholder participation.
Further reading:
- Thomas Krick, Maya Forstater, Philip Monaghan, and Maria Sillanpää, with Cornis van der Lugt,
Katharine Partridge, Charles Jackson, and Asaf Zohar. October 2005. From Words to Action: The Stakeholder
Engagement Manual. Volume 2: The Practitioner’s Handbook on Stakeholder Engagement. Available at AccountAbility,
www.accountability.org.uk; Stakeholder Research Associates, www.StakeholderResearch.com; United
Nations Environment Programme, www.uneptie.org.
13 Peter O’Hara, Enhancing Stakeholder Participation in National Forest Programmes: Tools for Practitioners. (Rome: National Forest
Programme Facility, Food and Agricultural Organisation of the United Nations, 2009), http://www.fao.org/publications/en/.
M&E was not robust so we WSIs can be difficult to monitor, as partners contribute in different and
couldn’t show the benefits. sometimes informal ways. This may result in challenges to attributing
[Civil society] outcomes to the WSI. Moreover, monitoring should focus on both the
efficiency of the initiative itself (including how participants cooperate)
and the progress toward achieving specific results. Without a robust
(From Field Testimony) monitoring framework and the systematic assessment of delivery against
the set objectives, WSIs are not able to prove their added value to the
public and its participants, as well as provide internal and external
accountability for the resources used. Moreover, weak monitoring
may lead to illegitimate claims by WSI participants (increasing risks
of “green washing”) and can be the cause for misunderstandings and
contradictory expectations on impact, outcomes, and contributions.
Having clear objectives within a WSI and the ability to track achievement
against these objectives supports corrective management and guards
against the manipulation or misdirection of resources, building overall
credibility. Transparency about what the WSI has achieved fosters exter-
nal trust concerning the motives of the WSI and its participants.
84 August 2015
and to generate lessons for the future. M&E frameworks should be developed by WSI participants, and
progress reviewed together to inform the development of the WSI and decision-making processes.14 M&E
provides the basis to hold WSI managers and participants accountable and can therefore contribute to
reducing mismanagement and capture.
Agree who is responsible for measuring the indicators and carrying out
evaluations, which forms and tools will be used, how frequently M&E
activities should be carried out, the resources available to do M&E,
Step 3: Make Monitoring a Joint
where the results will be reported, processed and responded to, and
Responsibility
how they will be disseminated. Use of external evaluators and public
disclosure of M&E frameworks and reports is recommended to ensure
objectivity and build credibility.
14 UNAIDS, Basic Terminology and Frameworks for Monitoring and Evaluation (Geneva: UNAIDS, Monitoring and Evaluation Division,
2010), http://www.unaids.org/sites/default/files/sub_landing/files/7_1-Basic-Terminology-and-Frameworks-MEF.pdf.
WSI
1: Incubation and Initial Analysis, 2: Formalization.
Phase
Y pays X funds and it’s not WSIs can engage the private sector to support, also financially, the
clear to the partners — it’s not development or implementation of water policies and services out of
transparent — the finances are their own business interest. This requires high transparency standards
hidden. [Civil Society]
and separation of roles in terms of financing and auditing vis-à-vis the
governance and decision-making structure of a WSI. Otherwise, WSIs
may run risks of capture, misleading expectations, or bad perceptions.
Does the corporation get Funding standards provide for a thorough due diligence investigation
to make all the decisions if of funders, including an assessment of possible conflicts between public
they are the major [financial]
and private interests. Financial management and audit protocols then
contributor? [Public sector]
ensure the follow-through and implementation of agreed arrangements.
86 August 2015
Guidance for implementation
▨▨ Through a due diligence of potential funders, WSI initiators can better understand their
motivations and identify potential integrity risks. Due diligence investigations should consider
real interests as well as perceptions, since the latter can have very damaging impacts on the
credibility of a WSI.
▨▨ In addition to the guidance on due diligence, the following aspects should receive particular
attention during the investigation of potential private funders:
▨▨ How transparent has the potential funder been about their particular interests, expansion plans,
Step 1: Conduct Due and the possible impacts of WSI outcomes on such plans? What are these possible impacts?
Diligence on Potential
Private Funders ▨▨ In terms of provision of WASH services, water use, and discharge, are the current and future
(planned) operations of funders in line with local and national policies and regulations, and with
international good practices of sustainable water management? What are the links between the
funder’s operational compliance with water regulations and the objectives of the WSI?
▨▨ Could the funding arrangement have (or be perceived to have) an impact on pending licensing,
concessional, or legal processes concerning the funder?
▨▨ Which conflicts of interests exist between the potential funder and other water users, and how
can these influence the WSI or its perception?
▨▨ Based on the due diligence findings, WSI initiators and participants assess whether they are
able to receive funds from the potential funder while maintaining the WSI’s integrity. As this
Step 2: Determine
discussion goes beyond a yes/no decision into designing possible integrity risk management
Credibility and
mechanisms for engaging with this funder, the due diligence shall provide a nuanced,
Integrity of Potential
dynamic understanding of the entity. Determining the credibility of funders should be done in
Funders
collaboration with all WSI participants as well as relevant affected stakeholders who may be
affected by the WSI or who may have special insight into the funder’s operations and intentions.
Step 3: Establish
▨▨ Before entering into a funding relationship, the WSI participants and the potential funder
Integrity Risk
should establish several preventive measures to manage sensitive areas that have been
Management Measures
identified (see box on Recommendations for WSIs).
with Funders
▨▨ Even if funding is diverse, a WSI should have a unified set of rules to manage expenditures, to
report to those overseeing the WSI, as well as for auditing. These rules should be agreed on by
all WSI participants as an addendum to the MoU or statutes of the governance body (as part of
the description of the body’s functions).
Step 5: Manage ▨▨ For general financial management and auditing, these will usually be the rules of the
and Report WSI organization that manages the secretariat of the WSI (or similar structure). The financial
Expenditures management capacities and possible risks need to be assessed in the process of formalizing the
role of the secretariat. If necessary, additional controls such as co-signature or no objections
for large expenditures and procurement should be put in place. For guidance on financial
management systems, see Instrument 2 of the Integrity Management Toolbox (Hermann-
Friede et al., 2014).
▨▨ Throughout the life of the WSI, participants should hire an independent party to intermittently
revisit contracts with private funders and assess their adherence to its agreements and
safeguards. This allows participants to continuously assess possible integrity risks.
Step 6: Continuously ▨▨ The scope and frequency of audits are designed to control the compliance of all parties with the
Audit Adherence to agreed funding arrangements. The process for an impartial recruitment of the external auditor
Contracts has to be agreed with funders (usually included in the financing agreement) and possibly with
other WSI participants. Audit reports have to be available to all WSI participants and should
be published if possible. For guidance on the recruitment, see Instrument 21 of the Integrity
Management Toolbox (Hermann-Friede et al., 2014).
1. Declaration of intentions and interests of WSI funder(s): These should go beyond the objective of the WSI
and clearly state the individual benefits that a funder expects from investing in the WSI.
minimum requirements
2. Financing agreement that separates the funding structure and the WSI operations: The results framework
of the agreement needs to be aligned with the general objectives and outcomes of the WSI. The release
of funds must not be bound to specific outcomes that benefit the funder. The funder shall not have any
special rights (e.g., veto rights) in the WSI governance structure. The implementing partners shall have to
justify only how money has been spent and how decisions on the use of funds have been taken, but not the
content of decisions (which may not always be in line with the funder’s interests).
3. Basic disclosure of information: Basic information on the overall budget of the WSI, the funders, and the
amounts each provides should be made available to the public.
4. Comprehensive disclosure agreements: The financing agreement and related (audit) reports should be
published and distributed to the utmost possible extent. If full public disclosure is not possible, other
options are to disclose documents only to WSI participants and/or to disclose key information only to
the public or WSI participants. Disclosing financial information is even more crucial in complex funding
structures.
highly recommended
5. Independent oversight: Engaging a social witness in the negotiations of sensitive financing agreements and
due diligence investigation of the funder can increase credibility. The social witness could be a community
organization or a national or international NGO. (For more info, see Tool 11: Independent Oversight.)
6. Who is paying what: In a WSI that receives a mix of public and private funding, it is advisable to use public
funds for sensitive WSI activities (e.g., development of master plans with direct impact on company
operations; assessments that serve as basis for prioritizing measures and intervention areas; travel of
public officials, community representatives and NGO partners with oversight function) and earmark private
funds for activities that are less sensitive to capture (e.g., the implementation of already agreed measures).
7. Funding diversity: To mitigate power imbalances and negative perceptions, equal possibilities to provide
funding should be assessed for all WSI participants, including those who engage at a later stage.
Especially if there are conflicts between different (corporate) water users, options to engage with all
parties should be explored and decisions documented.
88 August 2015
Tool 9: Managing Roles and Responsibilities within a WSI
Identifying the right people for the right roles within a WSI enhances Partnerships do not deliver
project efficiency and enables trust-based relationships among as fast as they should due to
lack of public sector capacity,
participants. Effectively managing roles also helps to avoid failures that
which has been the reason
could lead to inappropriate practice by individual participants, thus for the partnership in the first
protecting the WSI from integrity risks. For example, a company with a place. It still affects running a
keen interest in securing its own water supply vis-à-vis a WSI will likely partnership. [Private Sector]
not be a credible “neutral party.” In addition to aligning participants’
roles with their capabilities, effective delegation of roles ensures that all
participants play a meaningful role and that one participant does not Corporations have generally no
unduly dominate the development and implementation of the WSI. understanding of IWRM, the
context, where it came from,
Effective WSIs typically require fulfillment of a broad array of functions the critique; many of them are
to achieve success. At the same time, WSI participants bring with them ignorant of the whole technical
a wide array of expertise and resources, as well as areas in which they and management complexity.
have limited experience and capability. As such, well-defined roles and re- There is a risk of reinventing
sponsibilities among WSI participants that build on participants’ core wheels. [Civil Society]
competencies or are reflective of their main interests are critical to proj-
ect success. Though some organizations may initially join a WSI without
a clear understanding of their role in it, this arrangement should be tem- (From Field Testimony)
porary and the WSI should look to clearly delineate responsibilities and
expectations for all participants.
If there are no suitable candidates to cover a key responsibility, three options exist
to fill this gap:
Step 3: Identify and Reconcile
▨▨ Develop capacities within the group of WSI participants.
Unfilled Roles
▨▨ Seek new participants with capability and experience to fulfil this function(s).
▨▨ Bring in external support (e.g., consultants).
90 August 2015
ROLE Responsibilities Key Characteristics Questions to Ask
▨▨ Identify effective communication
channels
▨▨ Strong communication ▨▨ Can this individual or organization
▨▨ Develop a communication plan skills
WSI effectively communicate the
to reach external stakeholders
SPOKESPERSON ▨▨ Has trust of all objectives and ongoings of the
▨▨ Ensure relevant information is participants WSI?
available for all participants and
external stakeholders
▨▨ What kinds of external expertise
▨▨ Provide the technical and ▨▨ Strong research and
EXPERTS are needed for the WSI (hydrology,
analytical capabilities required analytical skills
political economy, etc.)?
▨▨ What is the funding model for the
WSI? Who is able to either provide
▨▨ Responsible for ensuring ▨▨ Access to significant
the funds or has the ability to
financial resources for the financial resources
FUNDERS or attract necessary funding?
initiative ▨▨ Able to find necessary
DEVELOPMENT ▨▨ Do these people or organizations
▨▨ Might provide financial resources funds for the WSI
PROFESSIONALS have the public interest in mind?
needed to support convening and ▨▨ Commitment to public
implementation ▨▨ Are they willing to provide funding
interest
without steering the WSI only in
their own interest?
▨▨ Identify anchorage points for ▨▨ When is a WSI ambassador needed
the WSI ▨▨ Familiarity with key to engage and/or embed the
actors and political initiative with local institutions?
WSI ▨▨ Feed information into existing dynamics
AMBASSADOR institutions ▨▨ Does this individual or organization
▨▨ Strong communication have the required political leverage
▨▨ Facilitate uptake of the initiative skills to effectively anchor the WSI
after its completion outcomes in the sector?
▨▨ Familiarity with key
basin actors
▨▨ Outreach to affected ▨▨ Do these individuals have the
COMMUNITY
stakeholders, especially those ▨▨ Credibility among local knowledge, trust, and skills to
ENGAGEMENT
who are typically under- communities engage with local community
OFFICERS
represented members?
▨▨ Ability to communicate
with local communities
PARTICIPANTS/ ▨▨ Assist project manager(s) in ▨▨ Technical capacity to
▨▨ NA
IMPLEMENTERS operations implement vision
▨▨ Degree of ▨▨ Does this individual or organization
▨▨ Oversee the WSI operations
independence from the have the resources and skills to
or implementation of specific
WSI provide independent oversight?
WATCHDOG agreements
▨▨ Strong understanding ▨▨ Does the WSI provide the avenues
▨▨ Ensure that the public interest is
of local context and for the watchdog to perform the
guarded
SWM assigned functions?
Source: CEO Water Mandate, Guide to Water-Related Collective Action (September 2013), http://ceowatermandate.org/wp-content/uploads/2013/09/guide-to-water-
related-ca-web-091213.pdf.
-Building Partnerships for Development (BPD). July 2011. “Power-Balanced Partnerships and Shared Incentives.”
Improving Partnership Governance in Water Services. (London: BPD Water and Sanitation). www.bpdws.org.
-CEO Water Mandate. September 2013. Guide to Water-Related Collective Action. http://ceowatermandate.org/wp-
content/uploads/2013/09/guide-to-water-related-ca-web-091213.pdf.
Internal written agreements allow WSIs to address integrity risks related to poor participant conduct,
inequitable decision making and communications, and potential financial management issues. These
agreements most often take the form of a Memorandum of Understandings and/or Code of Conduct, which
codify not only the objectives of the WSI but also the agreed to internal governance aspects and expectations
for participant behavior. In most cases, these written agreements will provide enough structure for a WSI,
particularly for cases where a partnership agreement is enough. However, when a WSI begins to develop into
a permanent organization, it may consider a number of different options. These options should take into
account the local legal context where the WSI is operating as well as existing institutions with whom the
WSI might engage.
Where functional multi-stakeholder partnerships or platforms exist, a WSI may emerge from such platforms
or be integrated into them to avoid parallel structures. In more informal arrangements, this could be to
operate as a working group, or more formally to enter into a partnership agreement giving the role of hosting
the WSI — and the secretariat, if needed — to the existing platform.
Partnership agreement
A partnership agreement between a range of stakeholders represents a commitment of resources from each
stakeholder toward meeting the objectives of the WSI. An agreement is best suited to the less intensive WSI
arrangements such as information sharing. The partnership may be formal, through the drawing up of a
contract between the parties, or it may be informal, through a forum with open engagement. It may evolve
over time and include the establishment of a WSI secretariat, typically hosted by one of the partners.
92 August 2015
Corporate entity
For profit: A company is set up as a separate body to manage and coordinate the activities of a
WSI. Companies are usually governed by a country’s Companies Act, which confers particular
regulatory requirements. For instance, a private company is a legal entity that must also register
as a tax payer. It is considered a separate entity from its owners or shareholders. Depending on
the size of the company, the managers may be different from the shareholders. Shareholders have
limited liability; however, under the Companies Act, liability is imposed only on those directors
who knowingly take part in an illegal or fraudulent act. Private companies are deemed to be more
stable, as they have a perpetual lifespan.
Not for profit: These are trusts or foundations. The most common types of non-profit organizations
(NPOs) are voluntary associations (VAs), trusts, and not-for-profit companies, which in many
countries are all governed by a Non-Profit Organization Act. A trust is an institutional arrangement
that is regulated by the common law and often by some specific legislation in the country, such as
a Trust Property Control Act. In addition to registering as a trust, a trust that also registers as an
NPO is recognized by the law as a corporate body with an independent legal personality.
Statutory entity
Statutory entities are public sector institutions governed by the laws of the particular country. Their ability
to act and implement activities suggested by the WSI is dependent on the activities stipulated within the
legal legislation developed for the entity. In many cases there are likely to be statutory entities already able
to carry out the WSI needs, rather than undergoing the tedious and often lengthy process of setting up an
additional statutory body.
Another option for the implementation of the WSI is to contract a third party or implementing agent. This
is not mutually exclusive of the previous options, but may be a useful option in implementing activities
for the WSI.
Practical tips An MoU expresses a convergence of will among the parties of a WSI,
indicating an intended common line of action. It is often used either
If it is not yet possible to define where parties do not require a legal commitment or where the parties
some aspects of the working
cannot create a legally enforceable agreement. Whether or not an MoU
relationship, preliminary
expressions of intent or other constitutes a binding contract depends on the presence of legal elements
such statements should be in the text such as the intention to be legally bound.
specified in addendums on how
gaps will be addressed later on. An MoU provides a reference in the event of dispute, differing interests,
or undesirable behavior by a participant. It also outlines and makes
It is important to clarify how
transparent the decision-making structure of the initiative, thereby re-
amendments to the MoU
will be agreed upon and how
ducing the risk of collusion that can lead to misuse of the WSI. Given its
additional parties can enter the formal character and the requirement that it be signed, the process of es-
MoU at a later date. tablishing an MoU contributes to raising awareness about the roles and
responsibilities of the WSI participants. MoUs can also mitigate reputa-
tional risks to the WSI and partners by specifying certain expected levels
of performance or adherence to good practice. For example, some MoUs
specify participant commitment to mutually agreed codes of conduct
(Tool 10b), environmental policy, or disclosure of conflicts of interest. Es-
tablishing a clear agreement can help prevent conflict and reputational
harm because expectations are established at an early stage, leaving less
room for misinterpretation by the participants.
94 August 2015
followed up with regular performance reviews. Ideally an MoU should be signed by all WSI participants
to create a level playing field and establish a transparent reference point. To create legal security, it can be
advisable to establish separate contracts (e.g., financing agreements) with individual participants for major
activities that require additional detail and legally binding contracts.
Where the WSI participants have chosen to enter into a contractual relationship, a change in responsibilities
is generally accomplished by signing an amendment to the agreement. To avoid spending scarce resources on
regular amendments to early contracts, it may be recommendable to establish bilateral expressions of intent
(or where appropriate, contractual agreements) for the process of forming a WSI and develop an MoU that
applies to all participants, once the initiative is formalized.
▨▨ Determine who the actual participants of the WSI are (i.e., the franchise
bottling company, the multinational beverage company, the ministry, a
Step 1: Link the Agreement to department of the ministry, etc.).
the Initiative
▨▨ Clarify how cooperation by a participant contributes to the
implementation of the WSI and what each participant can commit to.
96 August 2015
See page 25 for guidance on disputes. See page 27 for a
sample clause:
“The Parties enter into this [Name of Water Initiative] in a
spirit of collaboration and intend that all unforeseen matters
on issues that arise, as the relationship evolves, will be
resolved in a spirit of mutual understanding. If any dispute
arises between the partners relating to the [Name of Water
Partnership], the partners agree that they will first attempt to
resolve the dispute through direct and amicable negotiations
among the partner representatives. If such efforts to resolve
▨▨ Describe conflict resolution the dispute through negotiations fail, the partners agree to
arrangements or agree to jointly attend a conciliation meeting, facilitated by a knowledgeable
Dispute facilitator [consider naming a respected business person,
develop them in the near future, and
include them in an amendment. local leader, religious leader, university professor, etc.], to
discuss how the dispute can be fairly and equitably resolved.
Any partner may request a conciliation meeting regarding a
dispute by sending written notice to the other partners. For
such a conciliation meeting, the partners agree that they will
jointly select the facilitator, schedule a meeting at a mutually
acceptable time and location, and will attend and participate
in good faith. Parties anticipate that at such a conciliation
meeting the facilitator would lead a discussion about how
to equitably resolve the dispute and any underlying conflict
so that the activities of the [Name of Water initiative] may
proceed.”
See page 27 for further guidance.
Source: Barbara Evans, Joe McMahon, and Ken Caplan, “The Partnership Paperchase: Structuring Partnership Agreements in Water and Sanitation in Low-Income
Communities” (London: Building Partnerships for Development (BPD), November 2004), www.bdpws.org.
Further reading:
-Barbara Evans, Joe McMahon, and Ken Caplan. November 2004. “The Partnership Paperchase: Structuring Partnership
Agreements in Water and Sanitation in Low-Income Communities.” (London: Building Partnerships for Development
(BPD)). www.bdpws.org.
-Global WASH Cluster. 2009. “WASH Accountability Resources: Ask, Listen, Communicate.” (New York: Global WASH
Cluster and UNICEF. N.B.: See p.37 on for an example of an MoU.
For information on how to choose and draft dispute resolution clauses see:
-Public-Private Partnership in Infrastructure Resource Center (PPIRC). April 2008. “Dispute Resolution — Checklist
and sample wording.” http://ppp.worldbank.org/public-private-partnership/sites/ppp.worldbank.org/files/documents/
disputeresolution.pdf.
-cewas, WIN, and WASAZA. 2014. Integrity Management Toolbox for Zambian Water Sector SME: Description Integrity Risks, Version
2.0, p.89. http://www.sswm.info/content/integrity-management-toolbox-zambian-water-sector-sme-description-integrity-
risks
-Border Ladner Gervais (BLG). Summer 2012. “Choosing a Dispute Resolution Mechanism.” Dispute Resolution Newsletter.
http://www.blg.com/en/NewsAndPublications/Documents/Publication_3122.pdf.
98 August 2015
Guidance for implementation
▨▨ Drafters of the CoC need to learn more about the WSI and its context.
▨▨ Utilize a desk study to review and analyze public regulations and available
CoCs of WSI participants vis-à-vis the operating principles for integrity in
WSIs.
Step 1:
Analyze Available ▨▨ Complement the desk study with insights gathered from one- or two-day
Information interviews with stakeholders concerning which processes are prone to
integrity risks and hence which type of rules would be useful.
▨▨ Interviews can help to provide insight into work ethics, culture, and motiviation
of WSI participants and thereby identify values that should be expressed
through the CoC.
▨▨ The CoC should be shared with all WSI participants and affected stakeholders
for consultation.
▨▨ The consultation builds ownership and serves as a forum for planning
follow-up activities, including the integration of the CoC into the integrity
management of the WSI.
▨▨ Participants may consider a signing ceremony for the WSI, the official
Step 3: appointment of a focal person, and means of updating the relevant internal
Implement and Follow procedures that govern a WSI.
Up
▨▨ Review the code at regular intervals.
▨▨ Participants should be encouraged to address breaches of the code either with
the focal person or directly during meetings of WSI participants.
Develop a feedback mechanism that keeps all participants informed about the
number of complaints, types of complaints (e.g., serious, impact of the WSI), and
actions taken in response.
To get hesitant individuals on board for the development of a CoC and build confidence in it, participatory
integrity risk management exercises (see Tool 1b) can be helpful. In such a workshop, participants establish
the most relevant measures that should be implemented to ensure they are adequately managed.
•What types of sanctions will most likely lead to desired behavior and limit negative repercussions?
1. Warning: A Warning is notice, either oral or written, that continuation or repetition of conduct will be
cause for additional disciplinary action.
2. Reprimand: A Reprimand formally indicates to a participant that their behavior is unacceptable and
that continuing said behavior will warrant additional, more serious consequences.
3. Disciplinary Probation: A participant who is placed on Disciplinary Probation is notified that they
are not in good standing with the WSI. Any other violation of the CoC during the probation period will
typically result in suspension.
4. Restrictive Probation: Restrictive Probation is a notice to a participant that his or her actions are of
such a serious nature that removal from the WSI for a period of time is recommended. The WSI will refrain
from suspending the participant as long as he or she meets certain requirements. Any additional violations
of the CoC will result in immediate suspension and the possibility of additional sanctions.
5. Suspension: A participant serving a Suspension is removed from the WSI for a specified period, during
which they may not participate in any WSI activities or meetings.
6. Expulsion: This is a permanent termination of participant’s status and exclusion from WSI meetings,
privileges, and activities. Expulsion is communicated to all WSI stakeholders.
7. Restitution: This is repayment of funds to the WSI or to an affected party for damages resulting from a
violation of the CoC.
15 Barbara Evans, Joe McMahon, and Ken Caplan, “The Partnership Paperchase: Structuring Partnership Agreements in Water and
Sanitation in Low-Income Communities” (London: Building Partnerships for Development (BPD), November 2004), www.bdpws.org.
- GIZ Anti-Corruption Toolbox. (no date). “Codes of Conduct for the Private Sector.”
(Eschborn: Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH).
https://gizanticorruptiontoolbox.org/img_auth.php/f/f7/Codes_of_Conduct_for_
Private_Sector.pdf.
- International Federation of Accountants (IFAC). May 2007. “Defining and Developing
an Effective Code of Conduct for Organizations.” (New York: IFAC). http://www.ifac.org/
publications-resources.
- Australian Public Service Commission. (no date). Code of Conduct — Determinations
and Sanctions. http://www.apsc.gov.au/aps-employment-policy-and-advice/merit/
case-summaries/case-studies-repository/2011-12/code-of-conductdeterminations-and-
sanctions.
- WIN. (no date). Code of Conduct: Individuals, Organizations. Berlin: Water Integrity
Network.
- United Nations General Assembly. 1996. A/RES/51/59, Action Against Corruption,
Annex: International CoC for Public Officials (December 12). New York: UN General
Assembly. http://www.un.org/documents/ga/res/51/a51r059.htm.
Oversight refers to mechanisms that review institutional performance, Using political ward
paying particular attention to identifying failures in carrying out mandates, councilors as community
preserving participant discipline, and addressing inefficiencies. Without representatives is not
effective oversight, WSIs can be vulnerable to weak or biased institutional appropriate — they are
highly politicized, may just
performance, as participants inherently have vested interests in particular
use it for their own benefit.
WSI outcomes, and these interests at times conflict with the interests of [Civil Society]
other WSI participants or affected stakeholders.
Social audits
Social audits mobilize all affected stakeholders to systematically examine the impact of WSI performance
and policy outcomes, and to compare real achievements with public expectations. A social audit uses inclusive
and participatory techniques to involve all relevant stakeholders and feed the findings back to them. A
social audit can mitigate power imbalances and build trust in a WSI by providing downward accountability
to the affected stakeholders. It also enables effective stakeholder engagement at certain points along the
life cycle of a WSI.
Key factors for this mechanism are the openness of WSI participants and, usually, the involvement of a local
civil society organization with adequate technical skills in community involvement.
Further reading:
- GIZ Anti-Corruption Toolbox. (no date). “Social Audits.” (Eschborn: Deutsche Gesellschaft für
Internationale Zusammenarbeit (GIZ) GmbH). https://gizanticorruptiontoolbox.org/img_auth.
php/0/0b/Social_Audits.pdf.
- Civicus. (no date). Participatory Governance Toolkit: Social Audits. Civicus: World Alliance for
Citizen Participation. http://civicus.org/images/PGX_H_Social%20Audits.pdf.
- HELVETAS Swiss Intercooperation. (no date). “Public Audit Practice — Shifting the Focus of
Accountability Towards the People.” (Zurich: HELVETAS.) https://assets.helvetas.ch/downloads/15_
publicauditpractice_shiftingthefocus_blau_final_engl_a4_portrait.pdf.
- Joanne Caddy, Tiago Peixoto, and Mary McNeil. 2007. Beyond Public Scrutiny: Stocktaking of Social
Accountability in OECD Countries, pp. 105–107. (Washington DC: World Bank Institute). http://www.oecd.
org/gov/public-innovation/38983242.pdf.
- María González de Asís, Donal O’Leary, Per Ljung, and John Butterworth. 2009. Improving Transparency,
Integrity, and Accountability in Water Supply and Sanitation: Action, Larning, Experiences. Washington DC:
The World Bank and Transparency International. https://openknowledge.worldbank.org/bitstream/
handle/10986/2628/479680PUB0REVI101Official0Use0only1.pdf?sequence=1.
- Open Contracting. (no date). “In Mexico ‘social witness’ oversees public procurement.” Open
Government Guide. http://www.opengovguide.com/country-examples/in-mexico-social-witnesses-
oversee-public-procurement/.
16 The division of mandates between these varies from country to country and so must be individually assessed.
▨▨ Utilize a facilitated discussion among participants to explore the WSI’s overall outcomes
and the outcomes for each workstream and activity. In doing so, participants share
expectations, clarifying what they mean by success and how they would measure it,
what the lifespan of the WSI should be, and how they expect their contribution to evolve.
Utilize a proper M&E system to provide necessary clarity for such a discussion.
▨▨ Triggers that describe the benchmark to be achieved before moving on (e.g., percent of
Step 2: water user associations reaching a given level of functionality) may be adjusted during
Design the Exit the program cycle to reflect implementation constraints.
Strategy ▨▨ Choose metrics and define benchmarks for different groups to craft strategies that
allow for the withdrawal of participants interested in leaving the WSI following the
completion of their commitments.
▨▨ Ensure ongoing and timely monitoring of benchmarks and the conditions that might
prompt premature termination of a WSI to ensure successful implementation of the
exit strategy. Can be integrated into overall M&E framework for the WSI to avoid
duplication.
▨▨ Exit critera are drivers that prompt participants to make critical decisions affecting the
course of the WSI or the relationship with selected participants.
Step 3:
Moving On ▨▨ Table 12 focuses on the collection dimension of the exit strategy (how a WSI moves on).
It presents common scenarios and key features of the exit strategies implemented as a
result.
Action by
Driver Key characteristics of the exit strategy
participants
Redesign the program of Greater self-reliance (e.g., through increased efficiency or
1. Reduction in the WSI, its structure and new participants bringing different resources to the table)
or withdrawal of processes or handing over to existing local institutions.
resources
Abandon the WSI Participants leave the WSI or hand it over.
5. Perception of
Review the WSI; renegotiate program, participant,
new initiative Begin a new project cycle
structure, and processes.
potential
Adjust or terminate
7. Shift in context Review and readjust or terminate the WSI.
partnership
Participants inform and influence WSIs and their environment by defining objectives and activities, making
decisions, and executing activities. For WSIs to be genuinely effective in advancing SWM and to properly
balance legitimate interests, the selection, composition, and level of engagement of participants becomes a
key factor. Integrity, furthermore, describes a desirable form of behavior or conduct. In the context of WSIs,
this relates to participants’ choices and actions within and beyond the confines of the initiative. Although
WSI participants cannot be blamed for the questionable or illegal behavior of other participants, it is
important that WSIs react adequately in cases where illicit practices of individual participants are discovered.
Involving stakeholders with primary influence over the outcomes is essential for the success of WSIs, yet
it is important to consider carefully who participates in a WSI and to take adequate measures to ensure the
integrity of the initiative. To understand and prevent misconduct by individual participants, their roles,
values, and motivations to engage in collective action as well as their capacities need to be taken into account.
Based on Phase 2 project work, the following integrity risks have been associated with WSI participants:
Integrity
Description
Risk Area
The reputation and performance of a WSI participant with regard to integrity (including
compliance with policy and regulation, and how openly the participant has dealt with misconduct
track record and scandals) is an indicator for the organization’s professional behavior, ethics, and values. A
poor track record may have a negative impact on the credibility of the WSI and/or its participants,
and put the WSI at significant risk of failure.
The selection and composition of WSI participants should provide for adequate representation
of all stakeholders affected by the WSI and/or influential to the attainment of its objectives. If
proxies do not possess the mandate, legitimacy, or authority required to adequately represent or
representation communicate with these stakeholders, legitimate interests may not be adequately voiced. This
may simply lead to a poorly planned or executed initiative. Alternatively it may create avenues
for others to pursue vested interests or undermine informed decision making, accountability,
credibility, inclusiveness, responsiveness, and ultimately the delivery of beneficial outcomes.
The intentions behind an organization’s or individual’s engagement with a WSI influence their
intent and behavior as participants. The degree to which their motivations for engagement are aligned
incentives with the goal of addressing shared water risks and advancing sustainable water management,
therefore, co-determines whether they may misuse the WSI in pursuit of other interests.
People generally cross the line between honest and corrupt behavior when they have an opportunity to
misuse their power and when they feel pressured or tempted to do so. Transparency, accountability, and
meaningful participation in WSI governance helps reduce opportunities for corrupt behavior, because
it becomes increasingly difficult to cover up misconduct. Justifying vested interests that are in conflict
with other affected interests also becomes increasingly difficult if WSI stakeholders are well informed
and involved in planning and decision-making processes. Based on the results of the field assessments, the
following processes have been identified as vulnerable to integrity risks.
Integrity
Description
Risk Area
During the planning and design phase, the rationale, focus, content, and governance of a WSI
are defined. Inadequate, incomplete,or inappropriate planning processes are a significant
planning and
source of unclear and/or unsuitable objectives, and may result in inadequate stakeholder
design
engagement and weak governance structures that, in turn, lead to ineffective collective action
and increase opportunities for unethical behavior throughout the life cycle of a WSI.
managing WSIs have to be managed in line with their objectives. Poorly informed participants or weak
responsibilities, reporting mechanisms undermine balanced decision making and effective project design.
decision Unclear responsibilities, lack of oversight, discretion in decision making, and collusion among
making, and key participants are additional management-related risks that can facilitate the misuse of the
communication WSI by undermining its accountability.
Without proper monitoring, evaluation, and learning systems, participants can dishonestly
monitoring,
claim that they delivered outputs according to project plans if progress is not tracked
evaluation, and
systematically. This provides opportunities to siphon funds and to breach commitments and
learning
agreements.
The extent to which a WSI aims to enhance sustainable water management determines whether there
is a “stewardship” orientation or whether the WSI is focused primarily on advancing vested interests. To
ensure integrity, the objective or intent of a WSI must focus on enhancing SWM rather than pursuing vested
interests at the cost of public interest and resources. Given that they require significant investments, WSIs
should yield clear “societal value” for money.
WSIs should also avoid fostering unethical behavior or negative impacts beyond the confines of the WSI.
In this sense, factors need to be considered that influence the integrity of outcomes and of the impacts
WSIs have on their environment within the local context. Throughout the field assessments, engagement
with government and public authorities was identified as an important factor related to capture risks. The
function or purpose of a WSI equally influences its integrity. This is particularly determined by the extent
to which a WSI focus on causes rather than symptoms, and the types of WSI outputs — and their potential
negative impacts.
Integrity Risk
Description
Area
The degree to which WSIs are aligned with public policy priorities heavily determines
capture: the risks associated with the capture of public resources and priorities. Without proper
organizational analysis and alignment of the WSI with local policy context and targets, the use of
resources and organizational resources and public funds may be diverted away from issues of greatest
investment local priority and societal benefit, and toward addressing the priorities of private or
foreign entities.
Where WSIs engage in policy advocacy, convening, and debate, the resulting
representation, knowledge, or power imbalances may send advocacy messages that
advance the interests of certain private parties over public interest. Government
institutions are mandated to serve the public interest and should fairly balance
capture: regulatory
legitimate interests. As multi-stakeholder initiatives, WSIs provide a platform for private
action, policy, and
companies, business associations, NGOs, donors, and other participants to engage
water
with participants from public institutions. The types of government institutions and
the specific representatives that engage in a WSI influence whether and what type of
influence on policy and regulatory processes may result from the WSI, including risks
related to policy and regulatory capture.
Developing water (resource) infrastructure may result in integrity risks if social and
environmental impacts are not adequately assessed and safeguards established to
prevent harm. Perverse outcomes may also occur if multi-stakeholder groups to discuss
perverse outcomes and act on water issues are established without widespread legitimacy, or in competition
with existing legally mandated fora. Under these conditions, WSIs may have inadvertent
negative impacts on social equity or on the environment, or may undermine effective and
efficient institutional performance.
WSIs that only act on the symptoms of poor water management, without tackling the
causes of water challenges, have higher integrity risks related to the credibility of the
initiative as a whole. Projects that do not tackle a company’s effects on society and the
limited contribution
environment are commonly criticized as “green-washing” or “window-dressing” instead
to SWM
of taking responsibility for the corporate footprint. Indeed, different types of participants
may pursue vested interests to the detriment of other stakeholders, and disguise such
pursuits through a poorly informed multi-stakeholder process dressed up as a WSI.
Integrity Risks
1. Participant track record: A partnering company employs child labor, is involved in aggressive tax avoidance,
and is an ongoing polluter of the river, and so could bring the WSI and partners into disrepute.
2. Participant representation: Key stakeholders are not in the room. Communities living along the watercourse,
likely to be affected by degradation and with valuable insights on appropriate interventions, are not involved
and are not adequately represented by dysfunctional local government.
3. Capture of public resources: The WSI requirements of senior staff time are disproportionate to its narrow and
largely private benefit to their companies. The river stretch targeted is not used for water withdrawals and has
no strategic public value, yet a river 6 km away is severely polluted and affects the health of more than 300,000
poor citizens.
4. Participant intent: The tyranny of “allowance culture” means that public sector staff are drawn to externally
funded activities that pay sitting allowances, used to augment stagnating civil service salaries. These semi-
official financial inducements mean high public sector attendance at the meetings, but mask a lack of interest
in or relevance of the WSI.
5. Inadequate communication processes: Meetings are held in English, which prevents input by some local
stakeholders for whom English is difficult third or second language. Without their input, the project design
is flawed.
6. Monitoring, evaluation, and learning: No baseline monitoring is undertaken against which progress can be
tracked and lessons generated. There is no way to determine the benefits of the WSI.
7. Planning and design: A lack of rigorous and inclusive design means that the WSI focuses on the wrong issues,
with the wrong people in the wrong places. It turns out that corrupt local authority waste collectors are also
dumping in the river while taking payment for waste removal to the licenced disposal site.
8. Regulatory capture and perverse outcomes: Punitive enforcement work involving destruction of property
and forced re-settlement proceeds against vulnerable communities who live close to the river but lack land
tenure and funds to build proper latrines. The funding of public regulatory bodies by a group of private
sector actors (some of whom are polluters themselves) to undertake legal enforcement work represents undue
influence and unacceptable regulatory capture.
9. Limited contribution to sustainable water management: Although the lessons are intended to be scaled up,
the lack of any monitoring and evaluation means the WSI does not generate reliable knowledge. Neither is
the sharing of knowledge strategically planned into the WSI, with no process for or commitment to adopting
learning into wider-scale programs. The WSI has received sparse donor and government resources and has not
advanced sustainable water management.
17 This is a fictional river basin, and the problems have been developed to illustrate potential integrity risks. Any resemblance to actu-
al places, organizations, and people is coincidental and unintended.
The first stage of this project involved the development of a desk study that drew upon an extensive literature
review and bilateral interviews to help frame the issue of integrity in WSIs and fed into the development of
a field assessment methodology. The second stage involved an intensive field assessment and consultation
process to understand the actual integrity issues facing WSIs on the ground. These findings were used during
the project’s third phase to develop initial guidance and a framework with supporting tools for managing
the integrity of WSIs. The framework was subsequently tested via validation workshops and further refined,
resulting in this final guide.
Table 14: CEO Water Mandate Collective Action Working Group Members
Name Company
Hugh “Bert” Share Anheuser Busch-Inbev
Greg Koch The Coca-Cola Company
Lisa Schroeter The Dow Chemical Company
Emilio Tenuta Ecolab
Nandha Govender Eskom
Manoj Chaturvedi Hindustan Construction Company
Niyati Sareen Hindustan Construction Company
Elisabeth Swayze H&M Hennes & Mauritz
Stephanie Kotin Levi Strauss & Co.
Anna Walker Levi Strauss & Co.
Sanjay Banka Banka BioLoo
Paivi Makkonen Metsa Board
Christian Frutiger Nestlé
Carlo Galli Nestlé
Herbert Oberhaensli Nestlé
Naty Barak Netafim
Heather Rippman Nike
Dan Bena PepsiCo
Lauren Koopman PriceWaterhouseCoopers
Natalie Allan Teear PriceWaterhouseCoopers
Ryan Mullen PriceWaterhouseCoopers
Kevin Agnew Reed Elsevier
David Grant SABMiller
Andy Wales SABMiller
Martin Ginster Sasol
Capture
Public resource capture: Public resource capture occurs where public resources — whether civil
servant staff time, political attention, or organizational or departmental budgets — are diverted to
serve a narrow group of interests at the expense of the wider societal or public good.
Policy capture: Policy and legislative capture exist where private organizations unduly dominate
a policy-making or law-making process to the extent that other stakeholders’ views tend to be
excluded or considered less important, with the result that policy formulations or legal provisions
favor vested interests to the detriment of the public good.
Regulatory capture: Regulatory capture occurs where the agency responsible for regulation is unduly
influenced by or unduly favors the interests of certain stakeholders. This can result in favorable
handling, such as failure to vigorously enforce regulations, or inconsistent, non-proportional, or
selective enforcement.
Perverse outcomes: As used here, refers to WSIs that inadvertently exert negative impacts on social equity
or the environment, or that undermine effective and efficient institutional performance related to water
management.
Political economy: The interplay among economics, politics, and law, and how institutions develop in
different social and economic systems to manage the production, distribution, and consumption of resources.
It includes issues such as the distribution of power and wealth between groups and individuals, and the
processes that create, sustain, and transform these relationships over time.
Public interest: The welfare of the general public (in contrast to the selfish interest of a person, group, or
firm) in which the whole society has a stake and which warrants protection by the government. (Adapted
from BusinessDictionary.com.) As used here, the public interest benefits of WSIs are directly linked to
ensuring sustainable water management (see definition below).
Stakeholder engagement: A two-way effort to get involved and/or involve stakeholders in activities
and decision-making processes to ensure effective Water governance. Engagement happens at different
stages of an initiative and can take various forms depending on the degree of involvement of stakeholders.
(Source: Organisation for Economic Co-Operation and Development (OECD), “Stakeholder engagement
for Effective Water governance: Technical Note for the OECD Survey” (no date), http://www.oecd.org/gov/
regional-policy/OECDSurveyTechnicalNote.pdf.)
Stakeholders: Individuals, groups of individuals, and organizations that affect and/or could be affected by the
WSI’s activities. There are several main categories of stakeholders: (a) those that have an impact on you (e.g.,
regulators, protest groups, news media), (b) those upon whom you have (or are perceived to have) an impact
(e.g., nearby water users, neighbors, the natural environment), and (c) those neutral parties with no specific
link but with whom it is beneficial to engage. (Adapted from Alliance for Water stewardship (AWS), The AWS
International Water Stewardship Standard, Version 1.0 (April 2014), http://www.allianceforwaterstewardship.org/
assets/documents/AWS-Standard-v-1-Abbreviated-print.pdf.)
Theory of change: Refers to the building blocks required to bring about a given long-term goal. It is a specific
and measurable description of a social change initiative that forms the basis for strategic planning, ongoing
decision making, and evaluation. It can be seen as explaining how and why an initiative works; theory of
change analysis seeks to identify underlying assumptions about how change comes about, to make these
assumptions more explicit, and to test them. (Adapted from theoryofchange.org and Jesper Johnsøn, Theories
of Change in Anti-Corruption Work: A tool for programme design and evaluation, U4 Issue, no. 6 (October 2012), http://
www.u4.no/publications/.)
Vested interest: A personal interest on the part of an individual or group in a particular system, arrangement,
or institution with the expectation of personal gain.
Water challenges: Water-related issues that are of interest or concern to an organization, a site, or
stakeholders in a particular river, basin, or region, and which, if addressed, will provide positive impacts or
prevent negative impacts. (Adapted from Alliance for Water stewardship (AWS), The AWS International Water
Stewardship Standard, Version 1.0 (April 2014), http://www.allianceforwaterstewardship.org/assets/documents/
AWS-Standard-v-1-Abbreviated-print.pdf.)
Water governance: Formal and informal processes that allow for the determination and negotiation of
objectives, setting of standards, and resolution of disputes among disparate voices in order to address challenges
and meet objectives at local, subnational, and national levels in the management of water resources and delivery
of water services. (From UNDP Water governance Facility, “What is Water governance?” (2015), http://www.
watergovernance.org/whatiswatergovernance; and OECD, “Stakeholder engagement for Effective Water
governance” (no date, p.4), http://www.oecd.org/gov/regional-policy/OECDSurveyTechnicalNote.pdf.) Water
governance is defined by the political, social, economic, and administrative systems that are in place and
that directly or indirectly affect the use, development, and management of water resources and the delivery
of water service delivery at different levels of society. Governance is “good” when the actions (and inactions)
of all parties are transparent and accountable so that corruption is minimized, the views of minorities and
the most vulnerable are heard in decision making, and the needs of the present and the future are taken into
account. (From WIN, Introduction to Water Integrity, 2014.)
Water stewardship: The use of water in a way that is socially equitable, environmentally sustainable,
and economically beneficial, achieved through a stakeholder-inclusive process that involves site- and
basin-based actions. Water stewardship involves organizations taking shared responsibility to pursue
meaningful individual and collective actions that benefit people and nature. (Adapted from Alliance for
Water stewardship (AWS), 2010, “What Is Water stewardship?” http://www.allianceforwaterstewardship.
org/become-a-water-steward.html#what-is-water-stewardship.)
Water stewardship initiative: A coordinated engagement among interested parties (most often including
businesses) to address specific shared water challenges; a WSI typically involves structured collective action,
joint decision making, and joint implementation.
WSI initiator: A single organization or a small group of organizations that have identified the need to
work collectively on water in a defined geography and that begin a process of identifying the local water
challenges, opportunities, and potential participants to a WSI.
WSI participant: An individual or organization that is actively participating in the design and
implementation of a WSI. Participants can come from any sector but must have committed resources and/or
time to the initiative.
The Pacific Institute is one of the world’s leading nonprofit research and policy
organizations working to create a healthier planet and sustainable communities.
Based in Oakland, California, it conducts interdisciplinary research and partners
with stakeholders to produce real-world solutions that advance environmental
protection, economic development, and social equity — in California, nationally,
and internationally. Since its founding in 1987, the Pacific Institute has become
a locus for independent, innovative thinking that cuts across traditional areas of
study, helping make connections and bring opposing groups together. The result is
effective, actionable solutions addressing issues in the fields of freshwater resources,
climate change, environmental justice, and globalization. www.pacinst.org
Project Sponsors
DFID
The Department for International Development (DFID) leads the UK’s work to
end extreme poverty. It aims to end the need for aid by creating jobs, unlock
the potential of girls and women and help to save lives when humanitarian
emergencies hit. DFID works in 28 countries across Africa, Asia, and the Middle
East in the fields of education, health, economic growth and the private sector,
governance and conflict, climate and environment, and water and sanitation.
BMZ
GIZ
Collective Action
Mandate endorsers look to participate in collective efforts with civil society,
intergovernmental organizations, affected communities, and other businesses to
advance water sustainability.
Public Policy
Mandate endorsers seek ways to facilitate the development and implementation of
sustainable, equitable, and coherent water policy and regulatory frameworks.
Community Engagement
Mandate endorsers seek ways to improve community water efficiency, protect
watersheds, and increase access to water services as a way of promoting sustainable
water management and reducing risks.
Transparency
Mandate endorsers are committed to transparency and disclosure in order to hold
themselves accountable and meet the expectations of their stakeholders.
HUMAN RIGHTS
Principle 1 Businesses should support and respect the protection of
internationally proclaimed human rights; and
Principle 2 make sure that they are not complicit in human rights abuses.
LABOUR
Principle 3 Businesses should uphold the freedom of association and the
effective recognition of the right to collective bargaining;
Principle 4 the elimination of all forms of forced and compulsory labour;
Principle 5 the effective abolition of child labour; and
Principle 6 the elimination of discrimination in respect of employment
and occupation.
ENVIRONMENT
Principle 7 Businesses should support a precautionary approach to
environmental challenges;
Principle 8 undertake initiatives to promote greater environmental
responsibility; and
Principle 9 encourage the development and diffusion of
environmentally friendly technologies.
ANTI-CORRUPTION
Principle 10 Businesses should work against corruption in all its forms,
including extortion and bribery.