The workshop organised by UNODC on the implementation of the Anti-Corruption Strategy was an opportunity to share our assessment of the implementation of this document, as well as our efforts through participation in the National Anti-Corruption Council.
The workshop, held on July 1 in Podgorica, brought together representatives of institutions, civil society, and international organizations to discuss the current status of anti-corruption measures, identify challenges, and collect recommendations for effective monitoring and coordination mechanisms. Our representative, Dragana Jaćimović, who is also a member of the National Anti-Corruption Council on behalf of civil society, presented our observations in this regard.
During the presentation, we pointed out several key problems related to the implementation of the Anti-Corruption Strategy (hereinafter referred to as the Strategy):
– Unreliable and imprecise assessment of the baseline situation – Already at the time of the adoption of the Strategy in June last year, we highlighted the poor quality of the document, which was not the result of systematic and analytical preparation, noting that it was unclear on what basis baseline values for most activities were determined. For this reason, we did not support the adoption of such a document. The adoption of the Strategy, primarily to fulfill commitments made to the European Commission, appeared as a formal attempt to adopt a strategic framework. This was confirmed by the draft of the first report covering the six-month period from June to the end of 2024. The draft report confirmed that implementation of the Strategy cannot be properly monitored due to imprecisely defined benchmarks, nor is it possible to report on certain indicators, as also noted by the Operational Team in charge of monitoring the Strategy’s implementation. The draft also showed that institutions report without providing the required quantitative data; in some cases, activities are marked as completed without evidence of indicator fulfillment, or are supported by inadequate data. During one of the Council sessions, we pointed out problematic parts of the report, after which we were included in the Operational Team to help improve future reporting.
– Poor dynamics of the work of the National Anti-Corruption Council – The National Anti-Corruption Council, established in February 2024, held only two sessions in 2024, the last one in June 2024, when Montenegro adopted the new Anti-Corruption Strategy for the period 2024–2028 and the accompanying Action Plan. Following the adoption of the Strategy and the receipt of the IBAR (Interim Benchmark Assessment Report for Chapters 23 and 24), the Council did not meet for six months, despite our representative repeatedly initiating the convening of sessions. In the meantime, one civil society member resigned from the Council precisely because sessions had not been scheduled for months. Another CSO representative also left, leaving only our representative in the Council. The Council resumed work at the end of January 2025, holding four sessions this year. According to the Rules of Procedure of the National Anti-Corruption Council, sessions should, as a rule, be held once a month.
Delays were also recorded in forming the Council’s Operational Team, which is tasked with monitoring the implementation of the Strategy at the operational level and submitting quarterly reports to the Council.
– A thematic session left unfinished for more than three months – On February 28, 2025 (the Council’s fourth session), the National Anti-Corruption Council held a thematic session on corruption in the exploitation of natural resources (forests, gravel and riverbeds, quarries, and environmental protection). The session was interrupted with the announcement that it would be continued to adopt conclusions, but the continuation has still not taken place.
– Lack of transparency in the work of the National Anti-Corruption Council – In addition to irregular meetings, the work of the Council has been marked by poor practices, such as sending materials to members only a few hours before sessions, and by a lack of transparency. Council sessions are not announced on the official Government website, and only two out of six sessions held since the establishment of this Council have been publicly acknowledged.
Key Recommendations to Improve Monitoring and Implementation of the Anti-Corruption Strategy:
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The current Action Plan should be revised in order to define precise indicators, so that the degree of implementation of planned activities can be demonstrated through measurable results.
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Before developing an Action Plan for future years, a proper risk assessment of corruption should be carried out in areas identified by the strategic document as high-risk.
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The Council must increase transparency of its work through timely announcements of sessions and publication of information on sessions held. We also advocate for the publication of minutes from Council sessions.
Dragana Jaćimović