DFID Governance and Transparency Draft criteria and guidelines
Response from BOND to the DFID Consultation on
Governance and Transparency Draft criteria and guidelines
8 November 2006
About Us
BOND (British Overseas NGOs for Development) is the United Kingdom’s
broadest network of non-governmental organisations (NGOs) working in
international development and development education. BOND was founded in
June 1993, on the initiative of 61 NGOs, and now has over 280 members. It is
officially recognised by the UK’s Department for International Development
(DFID).
BOND submission to GTF consultation
BOND members welcome the draft guidelines on the Governance and
Transparency Fund, and the opportunity to actively offer our experience and
expertise by engaging in the consultation.
In general terms BOND members also very much welcome the Fund for its
focus on and commitment to the role of civil society as major stakeholders and
actors in governance issues, particularly on the demand side of governance.
We particularly appreciate the genuinely open and broad guidelines and
criteria, the long term perspective that the Fund adopts and the flexibility for
partnerships to evolve throughout the life of the scheme.
We have some areas of concern that have been discussed and agreed by
BOND members. We trust that these can be taken on board in the further
development of the Fund. The requested changes are summarised at the end
of this letter.
1. Governance of the Fund
We would like to see the administration of the Governance and Transparency
Fund be a model for good practice in governance and transparency. The
following issues were raised:
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A. BOND members believe there should be a civil society consultation
process on the Terms of Reference for the Managing Agent
(Guidelines, 3.1), particularly with relation to its own governance
structures and interests. It is recognised that DFID obviously has the
right to appoint its own managing agent. However, as this fund is very
particularly focused on the key issue of civil society engagement in
governance, BOND members feel it will strengthen the fund if there is
some civil society buy-in to the tendering process. This will build
confidence in the project selection processes and decisions later
adopted by the successful agent.
In light of the above, the tendering process for the managing agent
should make it feasible for a civil society organisation or consortium to
act as the managing agent. This approach is already successfully being
followed in a number of DFID funding initiatives in various countries.
B. We would like to see the establishment of a Strategic Advisory Group
or Civil Society Reference Group which includes recognised
governance experts from both the North and South. This will help to
improve the quality of decision-making within the fund through:
a. Helping ensure that appropriate and broad-based expertise will
influence strategic decision-making within the fund, critical within
what is by its nature a political area of work;
b. Demonstrating transparency and accountability by dealing with
these issues in a shared forum, not behind closed doors;
c. Developing buy-in to the fund by civil society in both North and
South, by recognising civil society expertise on governance
issues. This could increase the potential for joint-working and
sharing of learning, depending on the agreed role of the advisory
group.
C. In particular, the advisory group should have input into the design of
monitoring and evaluation structures for this Fund (Guidelines 3.10).
This group should be involved in developing key success criteria as a
basis for monitoring and evaluation. These success criteria need to
cover the range of levels at which programmes may be operating (e.g.
local, national, international). Again, BOND members feel the quality of
M&E work done through the fund will be improved by the managing
agent working with an advisory group, in addition to discussion with
grant recipients individually.
D. We would also like to understand more clearly the role that DFID will
play in the Fund, with relation to both the managing agent and to
funded partners. As DFID is an important actor at national level in
terms of governance and political processes, engagement with DFID
will maximise the strategic potential and impact of the Fund by allowing
participating consortia to leverage DFID's influence to improve civil
society access to policy dialogue spaces. This doesn’t mean only work
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directly related to DFID’s existing “supply side” support to governments
should be funded. Rather it means this work should be informed by and
support the impact and learning of civil society initiatives on the
“demand side”.
In addition, close involvement by DFID in GTF funded activities will
maintain DFID's grass roots contacts to support its high-level policy
engagement, as recommended in the recent DAC peer review of UK
Aid (June 2006). With these potential advantages in mind we would like
assurance particularly that:
i.
ii.
iii.
DFID will be, and will be clearly seen to be, accountable for
the selection of projects to be funded. For example, this would
include DFID being informed about all proposals; making final
selections from a shortlist provided by the managing agent,
rather than merely approving the managing agent's choice; and
in cases where the managing agent recommends rejection,
considering the managing agent's reasons for this;
DFID is prepared to make representations to the
Governments concerned where this can complement civil
society's efforts to tackle corruption and poor delivery of
services. NGOs' work to approach these problems from the
demand side will not be effective unless there are changes in
Government systems; and there may be cases where NGOs
working alone will merely provoke defensiveness and resentment
from the authorities.
DFID thematic and country experts will be involved in
monitoring and evaluating funded work, and DFID is fully and
actively involved at all levels in the programmes that it commits to
through the GTF.
2. Purpose of the Fund
BOND members would like to see a clear explanation of how this fund will
relate to other HMG and particularly DFID funds. We would like to be able
to understand the strategic coherence of this Fund with other civil society
funds such as the Civil Society Challenge Fund and the Conflict and
Humanitarian Fund, and with DFID’s other funding mechanisms such as direct
budgetary support. Our concern is to understand both how this will work at the
strategic planning level, and how specific in-country actions will be undertaken
to ensure complementarity between DFID’s work with national governments
and civil society activities funded by the GTF.
While we welcome both the openness of the Fund and the cross-cutting
themes of the Fund, we would welcome further clarity on how the criteria
for assessing and prioritising successful applications will be developed
within DFID's flexible guidelines. We are particularly concerned to see that
these reflect a realistic and appropriate analysis of the drivers and obstacles
for good governance in a given context. Specifically, we would appreciate
more clarity on the Quality of Governance Assessments (Guidelines 2.5) and
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how they relate to the Fund. Further, we would like to understand how the
criteria that are developed are rooted in DFID's anti-poverty mandate, and
retain a focus on explicit pro-poor development.'
3. Organisations eligible to apply to the Fund
The Fund guidelines appear to favour large organisations in a number of
ways:
 The minimum size of grant at £1 million;
 The requirement for a portfolio of projects delivered by a consortia of
complementary partners, with potentially only 10 months to develop such a
consortia, which may not be possible for smaller agencies;
 the implication that partners would be sub-grantees and
 the general stipulation that 85% of each successful proposal should be
granted to partners in developing countries, and the possibility that the
applicants will therefore have to cover some costs from their own sources
or other donors.
We believe that the guidelines as they stand will not encourage applications
from the full range of organisations that the Fund seeks to work with (see
paragraph 1.1), and in particular will exclude smaller NGOs and southern
organisations who may have particular expertise and experience to offer in
governance and transparency work.
We would like to suggest changes to the guidelines that would ensure genuine
participation and eligibility as applicants for a wider range of civil society
organisations. In particular:
 The guidelines should be further developed to allow effective participation
by smaller NGOs and/or civil society organisations which may have
particular strengths to bring to this work;
 We recommend that budget formats allow for the demonstration of the full
costs involved in a project, including allocated operational costs and any
co-financing proposed from other sources. This would ensure the costs of
the project could be fully funded from the grant and help provide a level
playing field between organisations with different capacity and income
levels;
 BOND welcomes the intention behind the 85%/15% criterion, but would like
to have reassurance that this will be applied flexibly, and in particular that
this will not be a barrier to applications by specific groups, including
consortia of smaller UK-based NGOs, with the additional costs involved.
 Given their role in helping citizens to hold their governments to account we
would like to request that media entities and local government be eligible to
receive funding as partners and clarification that non-registered
NGOs/CBOs could participate in funded activities;
 The Fund should make available some grants for amounts less than £1m,
and develop simple application criteria that maximise accessibility.
4. One funding round, 5-year timeframe
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BOND members are opposed to the plan to limit the fund to a single
funding round (Guidelines, 1.9). We appreciate the 5-year focus of the Fund
and recognise the need for sustainability, both of which are important to
effecting change in governance. However, doing this through a single funding
round at the beginning also raises some significant risks which we feel need
highlighting:
i.
ii.
iii.
Firstly, there is a risk that a single funding round will not allow for
sufficient learning to take place, both about the effectiveness of the
projects and programmes that are funded through the scheme and also
about the funding process;
Secondly, there is a risk that many agencies will not be willing or
able to invest the time and effort required to create really viable but
innovative consortia prior to developing proposals for a portfolio of
work, when they have no previous direction of what kind of work the
fund favours, and cannot resubmit proposals;
Thirdly, there is a risk that important but non-traditional civil society
actors may not be aware of the Fund in time for a one-time only
submission.
We would like to suggest the following as possible alternatives to the one
funding round model, which would better handle these risks:

Introduction of staggered funding rounds, which allow the Fund to
gradually open up to new relevant actors over time and for those actors
needing a long inception phase to apply;

Initial selection of programmes over 5 years but in two phases, with a
mid-term review to draw out learning and feed into decision making for
phase 2 programmes (some of which are extensions to phase 1, some
of which could be new);

Building in powerful mechanisms for learning, review and redirection
within a single round of 5-year portfolios, to capture the benefits of longterm commitment but also stimulate and apply lessons learned to
improve impact in changing contexts and scenarios;

Funding of a project inception period, to include research and
partnership development work, after which the longer-term portfolio of
work can be developed based on lessons learned during inception.
We believe the latter point would also encourage innovation and new alliances
between partners, further strengthening the work of the Fund and addressing
some of the concerns about accessibility to a diverse range of civil society
actors. We note that DFID funds inception periods for the Research
Programme Consortia supported by the Research Department, and that the
Big Lottery Fund also uses a similar approach for project funding: we
encourage DFID to examine these examples for lessons learned.
Finally, we would value further detail on how the fund will ensure longer-term
sustainability, in particular for smaller consortium partners whose
capacity to continue having an impact after GTF funding ends may be minimal.
We would welcome further information on DFID's vision for the long-term
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future of the GTF work, whether this includes a GTF2 or some other
mechanism for taking impact into the long term.
In summary, BOND is requesting the following changes to the GTF:
1. A stronger role for civil society (in the UK) in setting the terms of
reference for the managing agent, and participation in the design of
monitoring and evaluation structures for the Fund;
2. Creation of a civil society advisory/reference group for the managing
agent, including recognised governance experts from both the North
and South, with clear consultation roles, and involvement in project
selection processes;
3. Positive and active engagement by DFID in the Fund's activities and
functioning, including commitment of relevant expertise to guide the
Fund's work, and readiness to back up GTF impact with approaches to
relevant Governments on governance issues;
4. Clarity on coherence of Fund with other HMG funding mechanisms, and
on how the criteria to be developed for the Fund will ensure meaningful
impact on governance and poverty;
5. Greater clarity about the cases in which there would be flexibility to the
stipulation that 85% of funding received be granted to Southern based
organisations;
6. Availability of grants under £1m and simplified application criteria;
7. Inclusion of local government institutions, media entities and non legally
registered not-for-profit organisations/CBOS from the South as eligible
to apply for funding as partners of applicants;
8. Introduction of staggered funding rounds, inception phases and/or
learning and review processes within the 5-year time-frame, to
maximise learning from and fine-tuning of GTF-funded activities;
9. Clarity on how impact will be sustained over the long-term and
discussion around an extension of the programme and expenditure
beyond the 5-year timeframe
Contact
Dragan Nastic
Network Advocacy Officer
[email protected]
020 7520 0255
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BOND
Regent’s Wharf
8 All Saints Street
London
N1 9RL
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