WSI Integrity Risk Descriptions



Integrity Risks Related to Participants

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 Risk Area Examples
track record 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 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.
representation 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 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.
intent and incentives The intentions behind an organization’s or individual’s engagement with a WSI influence their behavior as participants. The degree to which their motivations for engagement are aligned 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.
capability Participants in a WSI ideally represent different constituencies, inform decision-making processes, and balance interests and power relations. Participants thus hold key functions in a WSI, whether to implement activities, monitor progress, control processes, and/or hold other participants to account. Where participants have limited capabilities to engage meaningfully in the WSI or to fulfil their responsibilities, they may contribute to poorly designed and executed initiatives, as well as be susceptible to manipulation, capture, or other forms of misconduct.
conduct Participants who do not value agreed procedures and fail to comply with policy and regulations — related to water management and other work areas — undermine the credibility of collective action endeavors. Low commitment or non-constructive conduct of individual participants is an impediment to fair process and outcome delivery, thus preventing WSIs from establishing professional processes and an environment of ethical conduct among cooperating organizations.
continuous engagement If participants in a WSI do not maintain a long-term commitment and engagement with the WSI, it becomes increasingly difficult to hold them to account. Poor engagement equally undermines the organization of a WSI and the implementation of practical action, eventually affecting delivery of envisaged outcomes.


Integrity Risks Related to WSI Governance

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 Risk Area Examples
planning and design During the planning and design stage, the rationale, focus, content, and governance of a WSI are defined. Inadequate, incomplete, or inappropriate planning processes are a significant source of unclear and/or unsuitable objectives, and may result in inadequate stakeholder 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.
stakeholder engagement Poor stakeholder mapping and (sometimes intentional) exclusion of affected stakeholders biases the objectives toward the interests of those who are actively implementing the WSI. Inadequate stakeholder analysis and engagement processes negatively affect decision-making processes and undermine the credibility, accountability, and responsiveness of WSI.
managing responsibilities, decision making, and communication WSIs have to be managed in line with their objectives. Poorly informed participants or weak reporting mechanisms undermine balanced decision making and effective project design. Unclear responsibilities, lack of oversight, discretion in decision making, and collusion among key participants are additional management-related risks that can facilitate the misuse of the WSI by undermining its accountability.
financial management Inadequate probity and transparency in financial planning, allocations, arrangements, and transactions put a WSI at risk by underming trust in the financial management of the WSI, which could lead to the misuse of funds for private gain or in the interest of specific participants. Participants who do not live up to financial commitments put the whole initiative at risk. Financial incentives and remunerations for WSI participants may also nurture corrupted or captured systems in public administration and among local water organizations. In some cases, where WSI participants are at the same time major WSI donors, there might be the potential for those participants to misuse their influence as donors to tailor the WSI to their interests.
monitoring, evaluation, and learning Without proper monitoring, evaluation, and learning systems, participants can dishonestly claim that they delivered outputs according to project plans if progress is not tracked systematically. This provides opportunities to siphon funds and to breach commitments and agreements.


Integrity Risks Related to the Context and Outcomes of the WSI

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 focuses on causes rather than symptoms, and the types of WSI outputs — and their potential negative impacts.

Integrity Risk Area Examples
capture: organizational resources and investment The degree to which WSIs are aligned with public policy priorities heavily determines the risks associated with the capture of public resources and priorities. Without proper analysis and alignment of the WSI with local policy context and targets, the use of organizational resources and public funds may be diverted away from issues of greatest local priority and societal benefit, and toward addressing the priorities of private or foreign entities.
capture: regulatory action, policy, and water 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 legitimate interests. As multi-stakeholder initiatives, WSIs provide a platform for private companies, business associations, NGOs, donors, and other participants to engage 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.
perverse outcomes 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 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.
limited contribution to SWM WSIs that act only 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 environment — that do not take responsibility for the corporate footprint — are commonly criticized as “green-washing” or “window-dressing.” 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.


WSI Integrity Risks Descriptions by Way of a Case Example

How it can all go wrong: The Kadee River Initiative

In a developing country where watercourses are often used as conduits for waste disposal, a company with an international brand initiates a WSI to clean up the river that flows from its production site to the ocean a kilometer away. The WSI involves other businesses (1), an international NGO and donor agency, national and local government (2). The work is well funded, well publicized, and gets high-level political buy-in and significant time commitment from senior managers (3) at the Ministry of Water and Energy, City Council, and National Environment Protection Agency. The initiative begins with a meeting with costs covered by the donor (4), and a programme of work is agreed (5). Work starts immediately (6), and the WSI commences with cash transfers from private sector funds to the local public authority to clear waste (7) and for enforcement work against poor sanitation infrastructure (8). The WSI intends to scale up learning at the basin scale (9).

Integrity Risks

  • 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.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.
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