Institute Alternative (IA) submitted to the authorities of Montenegro’s capital Podgorica comments to the draft Action plan for fight against corruption, finding that the document is not aligned with the national priorities and that it does not provide convincing justification of the proposed strategic aims, measures and activities.
The draft action plan of capital Podgorica does not offer a detailed analysis of current situation. By failing to recognize main problems and limitations faced during the fight against corruption at local level, this document doesn’t clearly identify the corruption risks. The legitimacy of chosen strategic aims, measures and activities is thus questionable.
The draft is based neither on the analysis of corruption risks carried out by the Ministry of Finance in 2011, nor on the Public Administration Reform Strategy and other relevant documents, including the most recent European Commission’s progress reports on Montenegro.
In addition, it should clearly state which of the measures from the previous action plan were not realized or were just partially implemented, and which the reasons for these failings are.
Justification of costs in the draft action plan is not satisfactory. The special part, which would clearly determine amount of money needed for realization of each activity, should thus be added.
It is senseless for the action plan to urge implementation of the valid legal acts, as it is outlined firstly in the introduction of the document, and then listed more specifically within the several measures. If the intention of the authorities was to highlight significance of implementation of certain acts and norms, it is possible to envisage specific models for following the implementation, which would include regular reporting and indications of challenges during the enforcement of specific rules.
We are concerned over the practical absence of the Podgorica’s local assembly from the draft action plan, apart from the one envisaged activity. Specific measures for enhancing the oversight role of the assembly should be also envisaged. In that respect, earlier recommendations of the IA could be useful.
Although highly susceptible to corruption, public-private partnerships and concessions are not included into the plan.
Numerous measures from the plan lack direct connection to the fight against corruption, while many activities and their stakeholders are not properly defined.The deadline for completion of many activities is imprecise, being simply defined as “continuously”. If not amended, all this can hamper the plan’s realization.