SPECIAL REPORT No 2/97 concerning humanitarian aid from the European Union between 1992 and 1995 together with the Commission's replies (submitted pursuant to Article 188c, paragraph 4, indent 2, of the EC Treaty) (97/C 143/01)

TABLE OF CONTENTS

Paragraph reference Page

1. INTRODUCTION . 1.1 -1.19 3

The humanitarian aid context . 1.1 -1.6 3

The establishment of ECHO . 1.7 -1.11 3

The Court's audit . 1.12-1.14 4

Allocation of aid . 1.15-1.19 4

2. THE COMMUNITY'S APPROACH TO HUMANITARIAN AID . 2.1 -2.28 7

The European Union's intervention strategy . 2.1 -2.10 7

Decision-making mechanisms and dispersal of financial resources . 2.11-2.18 8

Complementarity and coordination with Member State aid . 2.19-2.22 9

Cooperation with the United Nations and international organizations . 2.23-2.25 10

Conclusion . 2.26-2.28 11

3. MOBILIZATION OF HUMANITARIAN AID BY THE COMMISSION . 3.1 -3.25 11

Mobilization of appropriations (global plans) . 3.1 -3.7 11

Internal coordination of the Commission's aid measures . 3.8 -3.12 12

Identification of individual projects and appraisal of proposals . 3.13-3.18 14

Choice of individual operations . 3.13-3.15 14

Co-financing . 3.16-3.18 14

Conclusion . 3.19-3.25 14

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4. ECHO'S ORGANIZATION AND WORKING PRACTICES . 4.1 -4.52 15

ECHO's organization and resources . 4.1 -4.10 15

ECHO's working practices . 4.11-4.46 16

Framework partnership agreement (FPA) . 4.11-4.24 16

Tendering . 4.25-4.27 20

Monitoring the progress of operations . 4.28-4.40 21

Financial implementation procedures . 4.41-4.46 23

Conclusion . 4.47-4.52 24

5. EVALUATION OF THE AID . 5.1 -5.46 25

Internal evaluations by ECHO . 5.1 -5.5 25

Effectiveness of humanitarian assistance . 5.6 -5.40 26

Coverage . 5.7 -5.21 26

Appropriateness . 5.22-5.32 27

Impact . 5.33-5.36 29

Cost-effectiveness . 5.37-5.40 29

Visibility . 5.41-5.43 30

Conclusion . 5.44-5.46 30

6. OVERALL CONCLUSION . 6.1 -6.11 31

Clarity of the European Union's policy on humanitarian aid . 6.2 31

Consistency and complementarity of the European Union's aid . 6.3 31

Appropriateness of the means employed . 6.4 -6.8 31

Concentration of administrative responsibilities . 6.5 31

Increase in the capacity for intervention . 6.6 31

Improvement of the coordination with the other donors . 6.7 32

Mobilization of large-scale resources . 6.8 32

Procedures for evaluating and for rendering the accounts . 6.9 32

Final consideration . 6.10-6.11 32

List of abbreviations . 33

Notes . 34

Annexes . 37

The Commission's replies . 46

1. INTRODUCTION

The humanitarian aid context

1.1. Aid from the European Union to non-Member States includes a substantial humanitarian element which is earmarked for crises arising as a result of either natural disasters or situations of armed conflict. In recent years the European Community and the Member States together have accounted for about one half of total world humanitarian aid, and Commission expenditure has almost doubled. Annex 1 shows the commitments of appropriations and the payments made between 1992 and 1995. The majority of the aid measures were financed from specific humanitarian aid headings, namely Chapter B7-21 of the general budget 'Humanitarian Aid` (1) and Article 254 of the Lomé Convention (2). Despite the Commission's efforts to concentrate the financing of these humanitarian activities on budget headings specifically intended for this purpose, some other headings were used for aid measures which, contrary to what the Commission asserts in its reply, were of a humanitarian nature. Total annual payments increased from 335,3 Mio ECU in 1992 to 616,3 Mio ECU in 1995. For the whole period from 1992-1995 these payments amounted to 2 272,5 Mio ECU.

1.2. Apart from their extended duration, the other characteristic of the crises in countries such as Somalia, former Yugoslavia, Angola and Rwanda is the migration of large numbers of people to areas where resources are, in many cases, already scarce. The ensuing problems rapidly go beyond the immediate problems associated with the emergency, requiring mobilization of very costly resources, especially in the case of armed conflict.

1.3. The European Union's response is to involve a variety of bodies (3) in the mobilization of the financial resources which the Commission holds on behalf of the Union, and the Commission has to act as the catalyst by providing funds for all or part of the action undertaken by the various parties (4).

1.4. Several United Nations agencies (5) and international organizations, such as the International Committee of the Red Cross (ICRC), normally play a key role in organizing the aid effort. Unlike the European Union, which has its own financial resources, these agencies and organizations are heavily dependent on contributions from public and, to a lesser extent, private sponsors. The United Nations General Assembly radically reformed the coordination of its humanitarian aid provision by setting up a Department of Humanitarian Affairs (DHA) (6). Within the United Nations this Department is responsible for liaising between humanitarian agencies and also coordinating political, military (7) and humanitarian operations. Within that framework it launches coordinated appeals, the proceeds of which are subsequently distributed among the various agencies.

1.5. Hitherto the DHA has not always had the necessary authority to coordinate all the humanitarian aid systematically during major crises.

1.6. In this context, relations between the Commission and the DHA only very occasionally result in concrete action in the crisis areas. The cause of this can be attributed in equal measure to local conditions (Angola) and the DHA's lack of financial and human resources (Armenia, Georgia and Azerbaijan). The difficult relations between two of the main organizations called upon to act jointly in humanitarian crises are detrimental to the effectiveness of any action which they undertake.

The establishment of ECHO

1.7. Around the same time, the Commission was confronted with problems concerning the coordination, visibility and effectiveness of its own humanitarian measures. On 6 November 1991 it decided to create a special office which would be 'responsible for administering humanitarian operations to aid people in any non-member country who have been victims of natural disasters or exceptional events in cases calling for a swift response and/or implementation of expedited procedures`. The existence of this office was in principle restricted to a period of seven years, after which an in-depth assessment of its performance was supposed to be made. One of the purposes of this review was to explore the possibility of setting up an external, European-wide agency.

1.8. The European Community Humanitarian Office (ECHO) was thus set up initially to operate particularly in the area of emergency humanitarian aid to the people of third countries.

1.9. The Commission had, in fact, found that the Community's political will to take action in the area of humanitarian aid lacked visibility under the organizational arrangements which existed prior to 1991. At that time the organizations that were traditionally associated with the Community's action merely perceived it as a financial staging-post, whereas the Community saw itself as one of the lead players.

1.10. In setting up ECHO, the aims were:

a) 'focusing of administrative responsibility. . . to ensure managerial consistency and the expertise needed to handle emergencies and adopt the appropriate procedures;

b) capacity to take direct action at various stages, enhancing the Community's presence on the ground: identification of requirements, mobilization of personnel and material for the relief operation, monitoring and checks, ex-post evaluation;

c) improved coordination with the Member States, other donors, NGOs and specialist international agencies, notably through joint operations and framework contracts;

d) easier mobilization of the necessary budgetary resources in major emergencies' (8).

1.11. In January 1993 the Commission extended ECHO's mandate to cover the whole of its humanitarian aid, instead of emergency aid only. At the end of December 1994 the Commission set out ECHO's responsibility for emergency food aid and that of DG VIII (9) for programmable food aid.

The Court's audit

1.12. In mid-1994 the Court carried out an audit with the object of:

a) assessing the clarity of the European Union's humanitarian aid policy, its aims and the resources to be utilized;

b) examining the consistency and complementarity of the various instruments being used;

c) establishing whether the Commission was adequately equipped to implement the aid effectively;

d) verifying that appropriate procedures were in place for reporting under satisfactory conditions on the measures implemented and the results obtained.

1.13. The operations audited by the Court relate to the period between 1992 and 1995. The Court did not structure its audit by zone or country of crisis. Particularly at the beginning of the period covered by the Court's checks, the Commission for the most part responded to individual requests for funds from the humanitarian aid organizations. It was only later that the Commission began first to consolidate requests by countries/zone, and then to develop global plans (see various passages of paragraphs 3.1-3.7). The Court, therefore, focused its audit initially on the operational relations between the Commission and its partners. Annex 2 sets out the sample of projects selected for detailed examination.

1.14. The first stage was to review, at the Commission, the procedures followed for the choice of operations, the examination of project files, the conclusion of contracts and the monitoring and control of funds. This was followed by checks at the head offices of the Commission's main partners, with the aim of assessing the reliability of their management information systems and their bookkeeping procedures. A questionnaire on the Union's humanitarian aid policy and the Commission's practice was sent to 38 organizations in October 1994; 29 replied, many in detail. Interviews with the national departments responsible for the Member States' own humanitarian aid effort were used to assess the extent of collaboration between them and the Commission. Finally, the auditors visited Angola and former Yugoslavia (Croatia, Serbia and Bosnia-Herzegovina) in order to monitor the effectiveness of aid, on the ground, in the crisis areas. Regarding the crisis in Rwanda, audits of the files at ECHO's offices were supplemented by a review of the conclusions published in March 1996 by the Steering Committee for Joint Evaluation of Emergency Assistance to Rwanda, following the initiative of the Danish Ministry of Foreign Affairs at Copenhagen in November 1994.

Allocation of aid

1.15. The geographical distribution of European Union aid administered by ECHO from 1992 to 1995 is shown below.

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MED = Mediterranean countries

CEEC = Central and Eastern European Countries

NIS = Newly Independent States

ACP = African, Caribbean and Pacific countries>END OF GRAPHIC>

1.16. Analysis of the contracts concluded by ECHO, by type of partner, between 1992 and 1995 shows that the NGOs of the Member States, the United Nations agencies and other international organizations together received 83 % of the aid. A summary of the contracts for the same period, by partner category, is published in Annex 3. Annex 4 lists the 20 largest NGOs in terms of contributions paid by ECHO during that period.

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UNHCR = United Nations High Commissioner for Refugees

UNICEF = United Nations Children's Fund

WHO = World Health Organization

UNRWA = United Nations Relief and Works Agency for Palestine Refugees in the Near East

WFP = World Food Programme>END OF GRAPHIC>

1.17. Whilst the Commission is indeed responsible for implementing the European Union's humanitarian aid policy, some of the difficulties that have been encountered go beyond its capabilities and should not be held against it. In this particularly sensitive area, it is essential that all the parties involved, by common consent, implement measures that are devoid of any ambiguity. Whatever the difficulties encountered during the period 1992-1995, especially as regards the qualitative assessment of the aid's impact, it should be borne in mind that the Commission has succeeded in deploying an unprecedented amount of aid using relatively limited resources in particularly difficult areas suffering from armed conflicts. The European Union's contribution to the international community's urge to show solidarity is a major achievement for which the Commission must take the credit. Accomplishing this task has undoubtedly been facilitated by the setting-up of ECHO. Nevertheless, the Court's inquiries have highlighted various areas to which the Commission needs to devote further consideration and where it must improve its procedures.

1.18. Throughout the audit, the Commission's departments were regularly briefed on the Court's inquiries and the provisional findings of each of its audit visits. On several occasions, ECHO staff accompanied the Court's auditors on their visits. In some cases, staff from the Commission's departments themselves made subsequent visits to the partners whose operations had been examined by the Court in order to take stock of the checks which had been made. Initially, the provisional findings of the checks on each operational contract examined by the Court were notified to the Commission. Then, when the work was sufficiently advanced, two summary notes were sent to the Commission, one on the partnership agreement mechanism (November 1995) and the other covering the whole audit (February 1996). These various communications helped the Commission to target its own checks and to improve its own working methods. It is because of this approach adopted by the Court that some of the observations contained in this report have already been taken into consideration by the Commission.

1.19. In 1996, after the period covered by the Court's audit inquiries (1992-1995), the Council adopted two Regulations, one relating to humanitarian aid (10) and the other to rehabilitation and reconstruction operations in developing countries (11). These two Regulations set out some of the principles governing measures in the humanitarian field and therefore serve to remedy some of the shortcomings mentioned in this report. Their application is not widespread, however, as they are used for specific budget headings. As they have been adopted only recently, it is not yet possible to gauge their true impact. They are undoubtedly an important stage in the process of making the European Union's humanitarian aid policy clearer, but they do not constitute the final stage of this process, and, in the Court's view, cannot be cited as the definitive solution to the issues raised in this report.

2. THE COMMUNITY'S APPROACH TO HUMANITARIAN AID

The European Union's intervention strategy

2.1. The regulations adopted in 1996 lay down principles which are such that they make a serious contribution to clarifying the humanitarian aid policy pursued by the European Union. Nevertheless, the Court considers that the clarifications which have been made do not entirely cover all the aid measures of a humanitarian nature, whether it be the decision-making machinery, the eligible measures or the procedures for collaboration with international organizations. This appears to be connected with the fact that the Member States, whose individual positions may vary considerably, have not sought to establish an overall strategy for European Union humanitarian aid.

2.2. For example, up until June 1996, on specific questions there were in existence Council resolutions (12), resolutions of the European Parliament and the ACP-EC Assembly, Lomé Convention provisions and Commission communications (see paragraph 1.19). In addition to these various texts there are the Council's common positions (13).

2.3. In a joint declaration of 25 November 1994, the Council and the Commission expressed the view that a legal basis should, in particular, define the scope of action of a humanitarian measure, describe its coordination and set out the possibilities for cooperation between the Community, Member States and international organizations, including the DHA and NGOs.

2.4. In view of this the Council adopted the Regulation of 20 June 1996 concerning humanitarian aid (14). However, since its first objective is to create a legal basis for the implementation of the appropriations entered under certain general budget headings, it should have been stated that the Regulation is to apply to all the aid of a humanitarian nature in the general budget, and to the aid financed by the EDF as well (see paragraph 1.19).

2.5. The aim of Council Regulation No 2258/96 on rehabilitation and reconstruction operations in developing countries (15) is to meet the needs of people who have suffered serious crises or who are recovering from such situations and thus to ensure continuity of aid after the emergency, leading on to development. According to Article 1 of this Regulation, reconstruction and rehabilitation operations 'must progressively take over from humanitarian action` (see paragraph 1.19).

2.6. This wording could create an overlap between the terms 'humanitarian` and 'rehabilitation` which might give rise to duplication, omissions and, even, conflicts between the measures adopted. In this respect, the outcome of the crisis in Yugoslavia is an example of a situation where the Commission did not allocate responsibilities between its departments clearly. The Commission may be subject to pressure from some of its partners, and there is, therefore, a risk that this form of words may encourage the prolongation of humanitarian operations beyond what is necessary, under the pretext of continuity. The concepts 'humanitarian` and 'rehabilitation` should, therefore, be clarified in operational terms, at least as far as the measures financed by the Commission are concerned (16).

2.7. A proposal for a Council Regulation was submitted by the Commission on 4 September 1995 designed to provide a legal basis for implementing general budget appropriations to aid uprooted people (refugees, displaced persons and returnees) in Asian and Latin American countries (17). Article 1 of the Common Position adopted by the Council on 27 June 1996 states that 'The Community shall implement a programme of support and assistance to uprooted people to contribute to the urgent requirements not covered by humanitarian aid and for the longer-term realization of projects and action programmes aimed at the self-sufficiency and integration or reintegration of such people.` This draft regulation, therefore, introduces a further concept, that of urgent but not humanitarian assistance, which is not, however, defined any further. The distinctions between measures to be financed under this Regulation and those financed under the rehabilitation/reconstruction Regulation, or the humanitarian aid Regulation are not clear. It is symptomatic of the confusion that can arise that, although the draft Regulation states that it is concerned with (inter alia) urgent requirements not covered by humanitarian aid, in 1996 the budgetary appropriations have been placed in Title B7-21: Humanitarian Aid.

2.8. In its communication to the Council and the European Parliament 'Linking Relief, Rehabilitation and Development (LRRD)` (see endnote 16), the Commission recognized the potential problems that can arise from the implementation by different Commission departments of separate budget headings with separate legal bases for humanitarian assistance, aid to displaced persons in Asia and Latin America and aid for reconstructionrehabilitation. This Communication sought, amongst other things, to find a solution to these problems.

2.9. In order to eliminate these ambiguities and allow the Commission's partners to perceive clearly the objectives and resources of the European Union's humanitarian aid, it would be expedient for the latter to give an unequivocal global commitment, at the highest political level, on the basis of clearly-defined principles and in keeping with the provisions of paragraphs 1 (18) and 3 (19) of Article 130u of the Treaty establishing the European Community.

2.10. Without general guidelines there is a persistent risk of inconsistencies in the definition and implementation of the Union's policy.

Decision-making mechanisms and dispersal of financial resources

2.11. The European Union's decision-making procedures are a function of the origin of the financial resources, and not the nature of the proposed operations or the scale of the crises. It is thus possible for different procedures to be followed for one and the same operation.

2.12. In respect of the EDF, when the amounts involved have been small the Commission's response time has been short. However, when major crises have erupted (Somalia, Rwanda), the mobilization of appropriations has proved more difficult, especially where the allocations reserved for emergency aid had been used up. The mechanism whereby appropriations are transferred from financial instruments other than aid to refugees is not provided for by the Lomé Convention and obliges the Commission to implement exceptional measures (20).

2.13. The Commission split up some of the aid measures into instalments of 1 Mio ECU or 650 000 ECU, according to the circumstances. For this reason a series of decisions concerning amounts of 1 Mio ECU were adopted from 1993 onwards for Angola, Somalia, Liberia (21), Burundi and Rwanda. This is a purely administrative approach and when such an approach has been applied, it has complicated the planning of the overall aid approach (see paragraphs 3.1 to 3.7), added to departments' administrative workload and ultimately obscured the management control process.

2.14. The creation of an emergency aid reserve in the budget (22) has not functioned satisfactorily. This reserve, provided for in the conclusions of the Edinburgh European Council, was supposed to permit a rapid response to specific aid needs, resulting from events which could not be foreseen when the budget was established. In practice, however, the budgetary procedure applied has imposed a constraint on the implementation of the humanitarian aid programme.

2.15. Firstly, the appropriations initially provided for on the humanitarian aid budget headings were inadequate during the period of the major humanitarian crises in former Yugoslavia and Rwanda (1993-1995), so that in each year the Commission was obliged to mobilize the whole reserve. Secondly, the Commission only requested reinforcement from the reserve at a late stage. Thirdly, the transfers from the reserve were considerably delayed in 1994 and 1995. Further, as shown by the Court in its Annual Reports (23), this pattern of decision-making has contributed to very large under-utilization of payment appropriations, followed by very large carryovers to the next year when such carryovers should have remained the exception.

2.16. The Committee on Budgets of the European Parliament has concluded that either there should be a more rapid procedure for the release of the bulk of the reserve, or that the substantive humanitarian aid headings should be increased from the beginning of the financial year with a smaller volume of appropriations being put into the reserve (24). The continuing high level of needs for humanitarian aid that can be seen supports this second option.

2.17. Foodstuffs, a main component of the products supplied for humanitarian purposes, have, during the period covered by the Court's audit, been mobilized from a variety of budgetary sources and governed by different sets of rules. For example, in 1992, in former Yugoslavia, direct supplies of foodstuffs were simultaneously financed from the budget headings for emergency aid (B7-5000) and for the PHARE programme (B7-6000) and (by somewhat unorthodox procedures (25)) from European Agricultural Guidance and Guarantee Fund (EAGGF) appropriations. During the crisis in Angola, the bulk of the food products supplied by the Commission in 1993 and 1995, for distribution free of charge, was financed by Chapter B7-20 'Food Aid`, managed by DG VIII and DG VI, with only a few operations being financed from the specific humanitarian aid appropriations managed by ECHO.

2.18. Since the adoption of Council Regulation No 1292/96 of 27 June 1996 concerning the food aid policy and management (26), the food aid managed by DG VIII and DG VI is considered to be a structural instrument of food safety. Except in the case of large-scale crises requiring the use of all the Commission's instruments, the supply of foodstuffs under humanitarian operations should be covered by the appropriations from Chapter B7-21 'Humanitarian Aid`.

Complementarity and coordination with Member State aid

2.19. The concept of complementarity of Community aid and aid from Member States was written into the Treaty establishing the European Community, but it requires clarification. Although not all Member States devote substantial amounts of financial resources to humanitarian aid, certain of them are, however, able to deploy considerable physical and logistical resources. The Commission and the Member States should endeavour to bring these resources into play more effectively in connection with the implementation of humanitarian aid from the European Union.

2.20. The Community should also clarify what is meant by the term coordination as used in Article 130x of the Treaty (27) (28). Depending on the circumstances, the term can, in fact, cover very different measures and coordination may range from simple, one-way transmission of information to the systematic pooling of resources that have been mobilized in a coordinated way. It may also consist of making the best use of the capabilities of one or other of the parties, where they are relatively advantageous, by judicious allocation of tasks and resources (see paragraph 1.10).

2.21. Whereas in the area of development aid the Court of Auditors usually found that, on the ground, there was a certain amount of coordination between the Commission's representatives and those of the Member States (29), this did not apply to humanitarian aid. In the only case where large-scale operations were attempted (European Community Task Force - ECTF, see Box 1), cooperation dwindled rapidly, because of a lack of adequate commitment on the part of the Member States. The bilateral aid that was already in place was continued on an individual basis, alongside the ECTF, by the Member States concerned. In this context, in Croatia, at the end of 1994, there was found to be no effective coordination, with the result that bilateral food aid was distributed to the same recipients as the Community aid.

Box 1 - ECTF - European Community Task Force, Zagreb

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The ECTF was set up in October 1992 during the European Council in Birmingham 'to support the efforts of the UNHCR to deliver humanitarian aid to the former Yugoslav republics'.

Its objectives were:

2.21.1. to provide logistical and technical support to the UNHCR (although the latter was not consulted as such);

2.21.2. to improve coordination on the ground, principally by facilitating, between donors, the exchange of information on actions funded, with there being an implicit obligation on the Member States and the Commission to inform the ECTF of all their actions.

ECHO, by integrating its own bureau in Zagreb into the ECTF, gave it the additional objectives of implementing the direct food aid actions in Croatia and of supervising the Commission's partners.

From the outset, the planned information exchange proved difficult. Some Member States even initiated actions directly within the responsibilities of the ECTF without consulting it.

Despite declarations of intent, most of the Member States did not provide the contributions, and ECHO had to bear most of the running costs (5,62 Mio ECU between February 1992 and February 1996). As the Commission financed virtually all the running of the task force and as it was generally involved with its management, the ECTF in effect became the operational arm of ECHO in Croatia, Bosnia-Herzegovina and Slovenia. In doing so, the ECTF was generally perceived as an office of ECHO. According to an evaluation carried out by an external consultant, some of the Member State representatives did not understand the role of the ECTF, nor how it related to ECHO.>END OF GRAPHIC>

2.22. During the period covered by the Court's inquiries, coordination essentially took place at central level, at the quarterly meetings arranged by ECHO, in response to a Council Resolution (30), between the directors of the national humanitarian aid services. However, the minutes of these meetings show that the coordination had little concrete effect in the short term. Firstly, it consisted in providing the Member States with information on Commission financing decisions and the implementation of them. Then, it served to initiate discussion of various questions of principle, such as relations with the United Nations agencies. Some specific questions were also raised. On every occasion the Member States' representatives closed up whenever there was a possibility of anything more than an exchange of views, and suggestions for studies or coordinated action were referred to higher authority (see paragraph 1.10(c)). During the period 1992-1995, the Member States which systematically informed ECHO of their own humanitarian measures were the exception. This being so, unless there is a radical change in behaviour, there can be no extension of coordinated action between the European Union and the Member States because of the lack of adequate commitment on the part of the authorities in the latter.

Cooperation with the United Nations and international organizations

2.23. Cooperation with the United Nations agencies and international organizations such as the International Committee of the Red Cross are an important part of the European Union's humanitarian aid policy. Decisions at the highest level of the Union are required on how it should be put into practice. Framework partnership agreements such as those between ECHO and some agencies are inadequate in this respect, because their purpose is to set out the operational details for individual measures, rather than to lay the foundations for the cooperation provided for in the Treaty.

2.24. Although relations between the UNHCR and the Commission are long-standing, it was not until the beginning of 1994 that a high-level working party was set up in order to try to produce a more consistent definition of the procedures for operational and financial cooperation with the Commission. In order to boost its staff's coordination effort in the area of aid to refugees, displaced persons and returnees in third countries, the Commission set up a standing interdepartmental working party (GPIS) in November 1994. One of the working party's first objectives was to define the Commission's position vis-à-vis the UNHCR. By mid-1995 the working party was still not very active and its actual role had still not been defined.

2.25. Since the setting-up of ECHO, the UNHCR has acted as lead agency in former Yugoslavia and Rwanda. Although both agencies are covered by the same framework partnership agreement, cooperation between ECHO and the UNHCR has taken two very different courses on these occasions:

a) in former Yugoslavia, management of the food aid programmes was entrusted to ECHO in Croatia, to the WFP in Bosnia and to both at once in Serbia-Montenegro (31). In addition, the Community placed ECTF (32) logistical resources at the disposal of the UNHCR (Box 1) and financed a team responsible for evaluating requirements for the restoration of infrastructure in Bosnia (33). In other areas, the Commission treated the UNHCR as one partner among many and, between March 1992 and December 1994, ECHO entrusted it with the execution of agreements worth 379 Mio ECU;

b) in the context of the crisis in Burundi and Rwanda, the Commission financed its partners direct until the massacres in April 1994, when it began to channel a substantial part of its aid through the UNHCR (34). Under these new arrangements the UNHCR, in agreement with the Commission, shared out approximately half the sums received between the NGOs present on the ground. The agreements concluded were to be communicated to ECHO. In addition to improving coordination, the new system had the advantage of simplifying the Commission's work of administrative follow-up. In the case of a few large European NGOs (35) ECHO continued to provide funds direct, under the framework partnership agreement. At the same time ECHO sent a dozen technical assistants to these areas, to liaise with the UNHCR and other international organizations. At the end, the UNHCR was to make a report in accordance with the framework partnership agreement (see paragraphs 4.11-4.21).

Conclusion

2.26. As of the end of 1995 the European Union's humanitarian aid policy had not been set out clearly and there was no executive summary to apply to all operations irrespective of their source of finance (see paragraphs 2.1-2.6). The Council Regulations of 1996 concerning humanitarian aid and aid for rehabilitation, and the Commission Communication of April 1996 linking relief, rehabilitation and development are inadequate as a document setting out the EU's overall policy on all aspects of humanitarian assistance. That is why it would be preferable for the principles set out in these various documents to be consolidated. This could facilitate coordination with the bilateral aid from the Member States and the aid from international organizations. The consolidated document could form the Union's humanitarian aid charter, with a clear embodiment of the basic principles, guidelines, definitions and concepts, and laying down its specific characteristics in relation to aid from other donors.

2.27. Complementarity, like the coordination of Union aid with that of the Member States, still falls far short of the positions of principle set out in the Treaty and Council resolutions. Owing to the national administrations' cautiousness when applying the principle of complementarity to the European Union's humanitarian measures, the contacts between the Commission's departments and the national humanitarian aid authorities have failed to have much practical effect on the ground (see paragraphs 2.19-2.22).

2.28. Although the Treaty specifically provides for cooperation between the Commission and the United Nations (36), this collaboration is still unstable, partly because of the lack of any overall policy regarding the latter organization. A global agreement should be concluded with the Secretariat-General of the United Nations in order to ensure that relations between the Commission and the United Nations humanitarian agencies are consistent and transparent. Supplementary agreements could then be concluded with each agency (and the UNHCR and the WFP in particular) in order to clarify the prospects and practical procedures for collaboration between the agencies and all sections of the Commission (see paragraphs 2.23-2.24).

3. MOBILIZATION OF HUMANITARIAN AID BY THE COMMISSION

Mobilization of appropriations (global plans)

3.1. In times of crisis the Commission has normally responded on the basis of requests from its partners. For protracted crises, these requests for support have been consolidated by ECHO and have formed the basis for global plans on which the Commission decisions have been made. These global plans, the guiding instrument for ECHO's intervention in a given humanitarian crisis, set out a brief background of the crisis, the total financing proposed and the period covered by the plan (generally three to nine months), as well as details of previous funding and Member State allocations, if known. Also included is a summary of the organizations to whom funding is to be allocated, together with a sectoral analysis of the proposed actions. In protracted crises, the limited duration of the global plans has led to contracts being awarded with implementation periods that have proved to be too short (see paragraph 4.15 f). Although the quality of the information provided in the global plans has improved since 1995 (for example, details about priority areas), the plans examined by the Court before the setting-up of the Humanitarian Aid Committee were still incomplete.

3.2. In none of the cases which were examined for the period 1992-1995 did the global plans explain the medium-term strategy that had been adopted for the Community's aid measures, nor how it was to be coordinated with the strategies of the other main donors. It has thus been difficult to relate the priorities adopted by the Community in terms of the overall needs and to ensure that they were consistent, especially with those of the Member States (see paragraph 2.19). The global plans did not systematically specify the aid measures of all the Commission's departments, as these plans basically concerned ECHO.

3.3. Furthermore, it is not always possible to identify the negotiations leading to the overall amounts of financing to be raised. The Commission often confined itself to responding, fully or partly, to proposals submitted by partners, keeping within the limits of an amount of total financing determined beforehand and shared out in a manner that endeavoured to ensure a certain balance between the sectors involved, the groups of partners and the geographical origin of the NGOs.

3.4. The global plan of 18 Mio ECU decided for Angola in February 1994 included data only on humanitarian aid provided by ECHO and the DG VIII food aid unit. No details were provided on the DG VIII-managed rehabilitation plan, although this was an important element of the Commission's support (37). Furthermore, the ECHO global plan not only included actions of the same kind as those provided by other Commission departments, notably for basic health care and distribution of food products, seeds and tools, but also made no mention of how the actions which were financed were coordinated with those of the UN agencies and especially the WFP. The interaction between the global plan and the strategy of the UN Appeal was not mentioned. The target beneficiaries were not identified in terms of their status or location. In April 1995, the DHA coordination unit (UCAH) (38) asked the EU Delegate in Luanda to send it the coordinated strategy of the Commission in Angola. The global plan of 14 Mio ECU proposed in 1996 for the period May-December 1996 makes no mention of the 55 Mio ECU rehabilitation plan launched by DG VIII in early 1996.

3.5. In commenting on the Food Aid and Rehabilitation Aid programme in Azerbaijan between 1992 and 1995, a consultant engaged by ECHO pointed out that no comprehensive strategy had been defined and that the programme was a compilation of the requests of NGOs and other organizations working in Azerbaijan. ECHO's strategy paper 'Transcaucasus Humanitarian Assistance Strategy 1995` was seen by the consultant as an important step in establishing a sound strategy.

3.6. In former Yugoslavia, although broad objectives were identified for the proposed decisions, these were too general to constitute a precise strategy. For example, in the Commission decision of 100 Mio ECU of June 1993, the aims were to provide aid in the various regions (39), but without identifying the target beneficiaries in terms of status (40), nationality or geographical location, nor their needs and how these were being met by other organizations. The document did not define the EU policy towards the UN agencies or the ECTF (see Box 1), nor did it mention the existence of any privileged partners. Similar comments apply to the objectives set out in the decision of 156 Mio ECU of November 1994, where one of the objectives was to fund urgent rehabilitation activities, without these having been defined or located, despite the existence of the IMG-IBH which the Commission had already been financing since the end of 1993 (see endnote 33).

3.7. When the Commission adopts global plans, the NGOs' proposals for projects (see paragraph 3.1) may be put aside for several months before being included in series of financing decisions, for reasons relating to the decision-making process. The partners often see this practice as a source of complication: 45 % of the NGOs which replied to the Court's questionnaire (see paragraph 1.14) took this view.

Internal coordination of the Commission's aid measures

3.8. Several administrative departments of the Commission are involved in (see paragraph 3.12), and several sources of funding are available for, similar or related actions (see paragraphs 3.10 and 3.11). The UN agencies and many NGOs obtain funds under different Commission programmes, managed by different departments:

a) both the Food Aid department of DG VIII and ECHO provide significant amounts of aid to the WFP (see Box 3). However, it has only been since December 1994 that ECHO has actively participated in defining the position to be taken by the Commission in key policy-making Committees of the WFP, such as the Committee on Food Aid Policies and Programmes;

b) in Angola, in 1995, different Commission departments responsible for humanitarian aid, food aid and rehabilitation assistance were implementing programmes, sometimes through the same partners. There was insufficient coordination between the departments in Brussels and on the spot (see paragraph 3.4). Because of difficulties in sending information, the Delegation staff were not well informed about ECHO's humanitarian aid actions;

c) in the independent states of the former Soviet Union, the Commission is financing humanitarian aid, food aid programmes and the Tacis Programme. With regard to the 204 Mio ECU food aid programme provided to the Transcaucasian republics in 1994/1995, the ECHO-managed component (± 20 Mio ECU) was not coordinated with the food aid operation managed by other Commission departments.

3.9. The involvement of different Commission departments gives rise to two main issues:

a) the question of coordination of interventions between the Commission's departments, which must ensure that the total programme in a country is coherent and that there is no duplication or contradiction in the approaches of the different departments (see paragraph 3.10);

b) the question of the diversity of the various departments' procedures and contractual terms, which tends to increase confusion and inefficiency (see paragraphs 4.23 and 4.24).

3.10. Although there have been a number of institutional initiatives to improve inter-departmental coordination, these have had a limited impact (see paragraph 2.24) and, in practice, the most effective coordination in specific areas has come about through the efforts of individual desk officers. In its Communication of 30 April 1996 to the Council and Parliament on linking relief, rehabilitation and development (see endnote 16), the importance of the need for a global Community policy and coordination of departments to improve the efficiency and impact of actions was recognized. Community task forces, comprising officials from all the departments concerned, are to be set up at both headquarter and field level for a limited number of pilot countries (Angola, Haiti, Liberia, Somalia and the Great Lakes area). These task forces, also involving NGOs and UN agencies, are to formulate joint global framework policies for EC aid in the short, medium and long term for the countries concerned, and eventually for each region or country affected or threatened by a crisis. The global framework policies are also to establish the criteria and conditions under which each of the different departments will intervene.

3.11. The following are examples of NGOs which have received support from different Commission departments and have been faced with different procedures for managing the grants and drawing up implementation reports:

a) in Liberia, both DG VIII (EDF Refugee Aid) and ECHO financed the programme of one medical NGO during the period from July 1992 to June 1993 (1,3 Mio ECU). A similar case involving a sister organization also occurred in the same country during the period from March to September 1994 (1,4 Mio ECU). The terms and conditions applied by the two departments were different, which meant among other things that the NGOs had to prepare separate reports in different formats for the two departments. It would have been more efficient to use one source of funds only;

b) in Rwanda, during the period from August 1995 - January 1996, a legal NGO received a grant of 0,3 Mio ECU from ECHO to carry out registration activities in four prisons. Other activities, concerning defence of prisoners and training of legal personnel, were financed by DG VIII for an amount of 0,3 Mio ECU, from March 1996 to December 1996. These various activities still concerned the total activities of the NGO in Rwanda in one and the same field, but required different procedures to be followed depending on which Commission departments were involved;

c) in Angola, two NGOs, one medical and one involved in agricultural development, both received aid from ECHO and DG VIII rehabilitation aid at the same time. Although the activities were carried out simultaneously, they were governed by different implementing and accounting procedures.

3.12. One case was noted where similiar operations were being funded by different Commission departments: the 60 Mio ECU PHARE humanitarian aid assistance programme to FYROM (Former Yugoslav Republic of Macedonia), which was entirely managed by DG I A-B4, included a 5 Mio ECU programme to import essential pharmaceutical products in short supply, for distribution to hospitals, medical centres and state pharmacies. This was in essence similar to ECHO-managed projects in the same period, aimed at providing essential medical supplies in former Yugoslavia.

Identification of individual projects and appraisal of proposals

Choice of individual operations

3.13. In respect of the operations examined for the period 1992-1995, partners were not required by ECHO to provide precise information on the objectives and scope of the proposed actions and the targeted beneficiaries, but mainly to provide a list of personnel, supplies and services for which they were seeking financial support (see paragraph 4.14). In contrast with the procedures followed by the Commission departments prior to the establishment of ECHO, Commission delegation staff on the spot were not required to comment on these proposals systematically. The process of appraisal by ECHO staff in Brussels was reduced primarily to the choice of items that ECHO was willing to finance, but the files contained little information relating to the appraisal of requests or to the reasons for modifications to proposals, which sometimes seemed hard to justify (41). In 74 of the 104 projects examined by the Court, the way in which the project file had been prepared could not be clearly established.

3.14. Seven NGOs (which between them received 19 % of all funds allocated to NGOs during the period from 1992-1995) considered that greater attention needed to be paid to the pertinence and content of the proposed action. This is confirmed by several of the consultants contracted by ECHO to evaluate individual operations (see paragraph 5.12). At the end of 1995, ECHO tightened up its procedures for appraising its operations.

3.15. Furthermore, at the time of the Court's audit in 1995 ECHO had no criteria or organized records of previous experience with which it could determine the relevance of the action and the competence and efficiency of the potential partner (see paragraph 4.15 a). The files examined contained little or no evidence of why certain implementing partners were chosen rather than others. In paragraphs 5.22 to 5.28 of this report, the consequences of the inadequate initial preparation are set out. The revised procedures introduced in autumn 1995 whereby ECHO staff are required to document the preparation, follow-up and appreciation of each action should enable better targeting.

Co-financing

3.16. The Court is not opposed to the principle of earmarking funds for specific expenditure (42). However, it has found on several occasions that operational contracts formed part of a wider programme which was also financed by other donors. Of the 104 operations examined by the Court, 32 were of this type. In the case of major humanitarian operations in which a small number of donors is involved, it would be desirable for them, together with the partners concerned, to adopt a harmonized approach when defining the programme, with regard to their respective financial contribution and the joint system of reporting, monitoring and control.

3.17. The audit showed that one NGO was granted 12,6 Mio ECU to cover the cost of medical interventions in Bosnia-Herzegovina in the period from July 1992 to September 1994 and that during the same period, the organization received other grants, without the Commission's knowledge, from the United Kingdom and the UNHCR, and also received conditional funding of 4 Mio HFL (1,85 Mio ECU (43)) from the Netherlands Cooperation to complement the funds provided by ECHO. The same organization received 2,1 Mio ECU for its intervention in Liberia for the period from May 1993 to August 1994, in addition to grants from other Member States.

3.18. In 1993 an NGO submitted a rehabilitation programme in Northern Iraq for funding, informing ECHO that it was seeking funds from other donors, including a Member State humanitarian aid agency. ECHO agreed to finance a large part of the programme, but not the roads component, which was outside its mandate. This component was, however, an essential element in the programme. The NGO managed to obtain the necessary additional funds from four other sources. ECHO, in its monitoring of the project, showed interest only in the financial execution of the components which it had financed. At the end of the programme, only one of the funding sources (another NGO) requested a narrative and financial report covering the whole programme, showing total income and total expenditure.

Conclusion

3.19. Until early 1996 the global plans for mobilizing Community appropriations, drawn up periodically by the Commission as each major crisis arose, did not lay down a medium-term strategy for the aid measures financed by the Union. It was difficult to pinpoint the priorities and the main lines of coordination with the bilateral aid of the Member States. Consequently, these plans were often no more than lists of amounts of financing allocated to organizations designated by name, and so it was not possible to assess their overall consistency and to verify whether funds were being allocated to the most urgent priorities.

3.20. Where the contribution forms part of a programme and is not in reality a separately identifiable project, it is inadvisable to seek to impose administrative and financial control procedures which create pointless complications for the partner and for ECHO, and which give the impression of control rather than providing an effective control of the use of Community funds.

3.21. Control procedures for programmes form an area where increased cooperation between ECHO and Member States' humanitarian aid agencies is essential if more effective management of public funds in the field of humanitarian aid is to be achieved.

3.22. Although the Commission has made progress in assessing needs for individual actions, it is still largely dependent on the evaluations made by its implementing partners. Whilst taking account of the needs assessments drawn up by its specialized partners, the Commission, without duplicating work, should develop its capacity to acquire, in an independent manner, an overview of the needs in order to ascertain the relevance of the partners' proposals. In this manner, it could play a more active role in directing what action should be carried out.

3.23. In its appraisals of individual actions, ECHO needs to ensure that each proposal identifies clearly the objectives of the action and its scope, the strategy and action plan envisaged to achieve the objectives, the beneficiaries that are targeted and how the operation is integrated into any overall programme of aid involving other organizations. Indicators should be specified by which the implementation of the action plan and the impact of the measures can be judged. In situations of great uncertainty and rapidly changing circumstances flexibility is needed, but required changes to actions should be clearly motivated (see paragraphs 3.13 and 3.14).

3.24. Where ECHO and Member States are jointly funding an NGO's operations they need to agree on a much greater degree of information-sharing and on joint, programme-oriented verification procedures. In this respect, the OECD Joint Evaluation of Emergency Assistance to Rwanda (see paragraph 1.14) recognized that, whilst donors have a responsibility to improve accountability to the public, they should have an important role in promoting consistent standards for reporting (see paragraphs 3.16 and 3.21).

3.25. The various departments of the Commission also need to improve their coordination in the area of the examination and audit of the procedures and systems of the organizations to which they grant funds, in order to determine whether these organizations are able to manage and account adequately for the use of the funds they receive.

4. ECHO'S ORGANIZATION AND WORKING PRACTICES

ECHO's organization and resources

4.1. ECHO was set up at a difficult time, when major humanitarian crises were proliferating, thus requiring speedy responses to the problems of internal organization and to urgent external requests.

4.2. When it became operational in early 1993, ECHO took over not only the tasks but also a large part of the staff of other departments, in particular DG VIII/5 (emergency aid) and DG VIII/B1 (food aid). Redeploying the staff in this way enabled the office to begin its work straight away. However, quite a number of these staff left ECHO between 1993 and 1995. Several partners thus complained that those in charge of cases kept being replaced and that some of the new recruits lacked experience.

4.3. ECHO's organizational chart, drawn up at the end of April 1996, is shown in Annex 5. Annex 6 shows a breakdown of ECHO's staff and how they are divided up between the various departments on a geographical basis. The operational departments do not seem to have sufficient resources to cope with the needs for analysing and summarizing found in the field of individual measures (see paragraphs 3.13 - 3.18 and 4.26-4.27).

4.4. In recent years, because of a restriction on the number of posts available, ECHO has made considerable use of temporary staff, auxiliaries or persons providing services (44 staff in 1994 and 36 staff in 1995) for carrying out permanent day-to-day management tasks. At the end of 1995, 43 % of the staff had temporary contracts lasting a maximum of three years or 12-month auxiliary contracts or contracts for persons providing services, lasting between one and 12 months. The ECHO 4 unit (the former budgetary cell), responsible for committing appropriations and settling expenditure (general budget and the EDF), was thus run entirely by external staff, except for the head of unit and one official responsible for the unit's coordination. At the end of April 1996, more than 60 % of the staff in the financial unit were temporary (see Annex 6).

4.5. Temporary staff, auxiliary staff and providers of services had to deal with complex cases such as those concerning the crises in Rwanda (44), Somalia and Mozambique. When performing the job of desk officer, the external member of staff employed by the Commission becomes the main point of contact with the partners as he analyses the requests for financing and draws up contracts for the operations. Duties such as these should normally be carried out by experienced staff who have a good knowledge of the Commission's procedures and who, because they have contracts of considerable duration, can validly represent the Commission.

4.6. The procedures for recruiting staff not covered by the Staff Regulations are not very transparent. In the case of auxiliary staff (financed from Item A-110), as in that of providers of services (Item A-178) made available by temporary employment agencies, it is ECHO which presents the names of the staff to be recruited. They are chosen on the basis of personal intuition, without any selection criteria or tests to assess abilities.

4.7. As the contracts mentioned above are of limited duration, the only way in which the staff can continue to carry out the same tasks is by moving from one set of employment arrangements to another until they have reached the maximum length of service of three years. Once this period has expired, some staff may be granted a contract as a consultant financed from operating appropriations, but most of them, once trained, have to leave the department just when they have gained the experience needed to perform their duties. This being so, employing staff not covered by the Staff Regulations to carry out permanent tasks is unsuitable. In general, the regulations relating to the staff of the Commission, even those applicable to temporary and auxiliary staff, have proved to be too constricting where the mandate given to ECHO requires a degree of flexibility.

4.8. Since its creation, ECHO has recognized the need to have an increasing number of technical assistance personnel on the spot to evaluate needs correctly, to monitor and supervise the implementing partners, and generally to ensure a presence of ECHO in the field. During 1995, some 80 technical assistants were employed in 28 countries. These technical assistants are usually employed on short-term (six-month) renewable contracts. In practice, in some countries there have been frequent changes in technical assistance personnel. As a result, there is a danger not only that control of the operations financed by ECHO might be lost but also that its image as perceived by its partners might deteriorate. It is thus essential that the technical assistants whom ECHO employs on the ground are carefully selected, have considerable experience of humanitarian aid work and are sufficiently conversant with the way in which the Commission's departments work.

4.9. The role that the technical assistants are required to perform - coordinating with UN agencies and local authorities, and monitoring ECHO-financed operations - means in practice that they perform a representational function for the Commission. As technical assistants on short-term contracts, there are severe limits on what they can and indeed should do in this regard.

4.10. As Humanitarian Aid is a permanent programme of the Commission, there is a need to develop a capacity for representation in the field. An effective 'corps` of humanitarian aid experts, who could be deployed as required where humanitarian operations are carried out, and who could also spend periods at the ECHO headquarters in Brussels, would permit the Commission to strengthen its expertise. This should be done as part of a system of rotation of personnel similar to that in operation between headquarters and the delegations (45). In any case, the Commission needs to provide a much stronger institutional framework for its field supervision (see paragraph 4.37).

ECHO's working practices

Framework partnership agreement (FPA)

4.11. In order to be able to respond speedily and effectively to emergency humanitarian situations, the Commission, starting in 1993, has gradually set up a system of structured cooperation with its partners. This system, known as the framework partnership agreement, is based on establishing relations built on trust and on an agreement which lays down the detailed rules for granting ECHO financing and the procedures which its partners undertake to follow in order to account for their actions, in both operational and financial terms. This is not a closed system and does not prevent new operators from receiving financial support from the Commission.

4.12. The Court is in favour of the principle of a framework partnership agreement which is applied to partners whose effectiveness and reliability have been established and which is supposed to enable often large amounts of funds to be mobilized under good conditions, whilst at the same time curbing the periods of time usually needed for the administrative and contractual procedures. Indeed, in the past the Court has recommended that agreements of this kind be introduced, in the context of the co-financing of development projects with NGOs (46)

4.13. The framework agreement system consists of three parts:

a) the actual contract itself, a recital in general terms of the principles and intentions of the parties;

b) general conditions governing the procedures for appraisal, mobilization, rendering the accounts and payment. They lay down the form of the documents to be used for each individual operation;

c) specific conditions, laid down for each operation (47), which set out the work programmes and specify precisely which expenditure is eligible for ECHO financing during a strictly defined and usually short period.

The FPA is in practice concerned with the contractual conditions governing individual humanitarian aid actions, and does not cover more general conditions for a specifically designed longer-term partnership between the Commission and each of its partners in responding to humanitarian needs. Contrary to what the Commission states in its reply, the Court considers that, for the purpose of establishing genuine partnership relations which take into account the special features peculiar to each partner, the commitments of a general nature, mentioned in the framework partnership agreement, are clearly inadequate.

4.14. Whilst about a third of the NGOs questioned during the audit considered that the introduction of the framework agreement had indeed made their relations with the Commission easier by clarifying the financial procedures, the others took a less clear-cut view. Many of them perceived the framework agreement as an administrative instrument which was in some cases rigid and whose constraints were in fact felt only by ECHO's partners. They also thought that the FPA was an instrument basically geared towards quantitative checks on the purchasing, transportation and distribution of supplies (see paragraph 3.13). Quite recently, some of the large NGOs and the international organizations informed ECHO of the difficulties which they were encountering in implementing the framework partnership agreement and suggested some modifications to it. However, pending the Council Regulation on humanitarian aid (see paragraph 2.4), the agreements which expired at the end of 1994 have been renewed without any change being made.

4.15. The checks carried out at ECHO's main partners (Annex 2) have given rise to the following observations:

a) the partnership agreements have usually been made without ECHO having had the opportunity beforehand to make an in-depth analysis of its partners' working methods and administrative and financial procedures (see paragraph 3.15). This being so, ECHO has had no other choice than to propose just one approach to humanitarian aid, i.e. the approach which best satisfied its own budgetary and financial control constraints;

b) whilst the framework partnership agreement and its operational contract are well suited in their present form to simple humanitarian aid measures which basically involve procuring, delivering and distributing supplies, they are less able to satisfy the requirements of complex major operations which form part of longer-term programmes involving several donors. Similarly, whilst the very detailed budgets are in keeping with what may reasonably be expected for simple operations, this level of detail is, however, ill-suited to complex measures which call for a certain amount of flexibility. Whilst it is quite legitimate to want to ensure that the expenditure incurred corresponds to categories which have been authorized beforehand, it is going too far to try to stipulate the supplies too precisely, as this complicates the partner's action;

c) it is not realistic to take the attitude that the partner must in every case adapt to the donor's conditions because the latter holds the purse strings. This in fact runs contrary to the aim of sound financial management. The aid recipients either have to perform accounting contorsions which ECHO can detect only by means of on-the-spot checks, or they put ECHO in a fait accompli situation, safe in the knowledge that, because of their size and their political weight, they are key partners;

d) whereas in the framework agreement ECHO's partners undertake to follow certain procedures for individual measures, ECHO for its part makes only undertakings of a general nature. Thus, for example, ECHO does not specify the level of financing which its partners can expect, the time-limits within which they will obtain a response to their proposals or the explanations which will be given to them in the event of their proposals being altered;

e) some of the accounting methods applied by the ECHO departments are not very explicit and result in cases where ECHO refuses to bear expenditure even though there is no question as to the availability of the appropriations or the relevance of the expenditure. The following aspects of the framework agreement should therefore be explained more clearly: the detailed rules for applying the flat rates, especially for staff expenditure (see paragraph 4.22), the mechanisms for using the contingency reserves, the arrangements for reviewing the budgets and the procedures for converting advances and expenditure (48);

f) since the operational contracts relate to measures which are complex or part of large-scale aid programmes, the set time-limits for the eligibility of expenditure are often too short and do not correspond to the real duration of the measures (49). In 41 % of the operational contracts which were examined, the contractual periods proved to be unsuited to the partners' constraints. For the convoys organized by the Danish Refugee Council in former Yugoslavia, ECHO, for example, made 25 agreements between June 1992 and September 1994. Even though this may be an extreme case, it shows that where the duration of the contracts is insufficient, this complicates the planning and management of the aid measures and thus leads to loss of effectiveness and unnecessary costs;

g) expenditure is not finally settled until a narrative report on the implementation of the measure has been submitted. However, whilst the financial statements of costs are subject to very strict checks on their compliance with the budgets or as regards the dates of issue of the invoices, in none of the cases examined during the audit was it found that ECHO's departments had sought explanations when the reports were too vague or else too brief for the real extent of the implementation of the work programme to be judged (50).

Box 2 - Application of the framework partnership agreement to the UNHCR

>START OF GRAPHIC>

The main observations arising from an examination of the agreements made in respect of the aid measures in former Yugoslavia for 237 Mio ECU are as follows:

a) ECHO did not make any general contribution to the UNHCR's action programmes, but financed individual measures within these programmes. In practice, ECHO links its financing more to pre-determined measures than do the other donors. This practice is ill-suited to UNHCR's mode of operation and creates grave administrative and accounting difficulties for the UNHCR, because the financing is so brief and unpredictable in the medium term;

b) because of the war situation, the UNHCR's estimates of needs for equipment and provisions have remained very rough and have included the setting-up of reserve stocks in order to cope with contingencies. For its part, despite being represented on the spot, ECHO has often been unable to assess the validity of the requests submitted by the UNHCR;

c) even though the UNHCR's ability to monitor the final distribution of goods on the spot was limited, ECHO accepted implementation reports which were very general and whose information value was low, despite the fact that only the individual operations were regarded as eligible;

d) despite the size of the amounts involved, ECHO has not obtained from the UNHCR independent evaluations of the operations financed.

For the crisis in Rwanda, an examination of four agreements made with the UNHCR for a total of 73 Mio ECU gives rise to the following observations:

a) the Commission's agreements do not correspond to the UNHCR's programmes of operations; this is simply a consequence of the fact that the Commission has made appropriations available gradually;

7Y0512(01).1

b) by deferring the expiry of the agreements by several months and accepting that only one overall report be submitted for the four agreements, the Commission has adapted the standard system which it initially set up to the operational needs of the UNHCR in this crisis. ECHO's various contributions can be seen as a piecemeal response to a global appeal, a system which the Commission is usually against;

c) the UNHCR has not always responded to ECHO's requests for information: for example, as at September 1995 it had not sent ECHO all the agreements made with the NGOs;

d) because of the large number of operations and because the detailed information is dispersed, the system which ECHO has set up does not enable it to exercise its operational and financial control under the conditions provided for by the framework partnership agreement. Notwithstanding these points, the manner in which the Commission provided block funding to the UNHCR in Rwanda was judged effective in the circumstances by the evaluators mentioned in paragraph 1.14 above.>END OF GRAPHIC>

4.16. However, although the purpose of the framework partnership agreements is to establish cooperation which is geared towards effective action, simplified administrative procedures and a higher profile on the scene of crises, the number of these agreements tends to be restricted by two constraining factors: ECHO's limited human resources and the need to have a thorough knowledge of its partners' capabilities and working methods.

4.17. The system of the framework agreement, as implemented, serves basically as a formal support for the submission of draft budgets and then as an accounting control instrument for expenditure. At the very most it was permitted that the supporting documents would no longer be sent to ECHO at the time of the final settlement, but would be kept at the partners' headquarters for subsequent verification if need be. So long as the partners' constraints and operating conditions are not taken into account and the same treatment is applied to them all, the framework agreement will fail to be any more than a reasonably suitable instrument for rationalizing procedures for appraisal and for settling expenditure within the framework of subcontracting relations for purchases of supplies and services. In respect of the Commission's reply, the Court would point out that, like the European Parliament and the Council, it unreservedly supports the principle of a framework partnership agreement as an instrument for managing humanitarian aid (see paragraph 4.12). However, in the way it is at present worded and being applied, it will not be seen as an instrument leading to an effective partnership geared to aid objectives to be achieved by means of acknowledged know-how in specific areas (see paragraph 4.16).

4.18. The above observations, together with those set out in paragraphs 3.16-3.18 concerning co-financed operations, point to the need for the Commission to introduce some differentiation into the provisions of the FPA to reflect the different types of operation being financed. This should be done as part of the process of amending the provisions of the FPA already begun in 1994 but postponed while the humanitarian aid Regulation was prepared. Where the operation is a relatively straightforward one, involving the procurement, delivery and distribution of humanitarian supplies as a self-contained action, then the existing FPA provisions, with the improvements already under consideration, are appropriate. For more complex actions, where the resources provided by the Commission are combined by the partner with the resources of other donors and the own resources of the partner, the contractual terms need to be more explicit about the total programme, the different components of that programme and the sources of funds that will cover it.

4.19. As a major donor it is normal that the Commission should be closely involved with the definition of the programme or its partners, and should be able to influence priorities. The FPA conditions for this type of contract should be precise about narrative and financial reports - form and content - that will be supplied at the level of the partner's whole programme, so that the partner is sufficiently accountable to its donors. Also, such contracts should include audit arrangements for the operation as a whole, to avoid the situation where each donor seeks to apply its own audit requirements in isolation.

4.20. In order for this to be effective, other major donors would need to agree on a similar approach, which is unlikely to be easy. Nevertheless, the Commission and the Member States of the EU are in a position to take a lead in this area. The Joint Evaluation of Emergency Assistance to Rwanda made specific recommendations to donors, agencies and the OECD/DAC on the need to define 'consistent standards, including adequate breakdown of data by activity and area, for the humanitarian assistance community as a whole.. . . Donors have a responsibility to standardize among themselves the formats they use for reporting requirements of agencies to whom they provide funding` (51).

4.21. Differentiation of the contractual terms of the FPA on the lines set out above implies a degree of differentiation by groups of organizations with which the Commission works. One group consists of the major UN agencies and the ICRC, with whom particular agreements are needed both because of operations financed, and because of their particular multilateral and international status (see paragraph 2.23). A second group consists of the NGOs operating on an international scale, with medium or long-term programmes of humanitarian assistance in a given country, for which they obtain funding from several sources. A third group consists of NGOs which implement individual humanitarian actions, normally on a limited scale and with simple financing formulas.

The personnel costs of projects

4.22. Frequently, personnel expenses constitute a major part of the costs of a project. Unlike the purchase of goods and materials, where ECHO requires details of actual costs, a system of flat rates (52) is used, with different rates for expatriate and local personnel. As currently applied, the system suffers the following problems:

a) although the term used is 'flat rates`, and in practice ECHO pays the standard rates in full, it has tried to argue (53) that what is in fact meant is that the 'flat rates` are ceilings up to which payments will be made;

b) the remuneration actually paid by ECHO's partners to their staff varies considerably: for some, the flat rates are insufficient to cover the costs (e.g. the UN agencies, international organizations and some NGOs which pay near-professional rates), while for others, whose staff work for volunteer rates, the flat rate sometimes exceeds actual costs substantially (54);

c) the rates for local personnel are also standardized across the world, and are based on the levels of pay in the poorest countries (55). They are totally inappropriate for middle-income countries such as former Yugoslavia. A majority of the partners contacted considered the local flat rates far too low to enable them to appoint good local staff, especially in highly-qualified professional categories. In these circumstances, there is an incentive for partners to appoint expatriate personnel rather than local staff, which penalizes both the country in crisis and the budget of the Community.

Standardization of contract terms and conditions

4.23. The Commission has not standardized its contractual terms and conditions for its partners receiving funds for humanitarian aid actions managed by ECHO (governed by the FPA), food aid operations managed by DG VIII (the Official Letters), refugee programmes managed by DG 1B and DG VIII (letter contracts), and the co-financing of development projects with NGOs, managed by DG VIII (letter contracts). About 45 % of the ECHO partners consulted pointed out that they did not understand the reasons for the considerable variation in procedures. While it is true that contract formats, terms and conditions cannot be strictly identical for the different types of action financed, there is scope for considerable standardization and improved coherence between the requirements of the Commission's different departments, notably in the following areas:

a) payment conditions (for example, advances, conditions for release of funds);

b) other financial conditions, including treatment of interest (56), payment of flat-rate amounts for personnel or transport;

c) procurement rules;

d) inspection and surveillance;

e) transport and delivery conditions;

f) provisions concerning the presentation of narrative and financial reports, including the deadlines specified.

4.24. The Commission has recognized that the application of different procedures, including contractual ones, in the administration of refugee programmes is unsatisfactory (57). In 1994, the Commission departments involved with refugee actions examined whether the FPA was applicable to their longer-term actions, but found that it was not. Since then, there has been little progress towards harmonization of contractual conditions. The review of the terms and conditions of the FPA by the Commission should explicitly take this into account.

Tendering

4.25. Generally, it was found that the large organizations, such as the UN agencies, the ICRC, the large NGOs, apply appropriate procedures for market-testing and tendering, and seek to obtain the best offers in terms of price, delivery, reliability of supply, and similar criteria. These organizations, including the large NGOs, generally have specialized procurement departments and keep their procedures under review.

4.26. With regard to the procedures followed by the Commission, out of 20 operations examined by the Court (58) those carried out by two organizations showed procedures which fell short of what should be expected:

a) the first case concerns contracts for the supply of food parcels to Serbia. Although this was in practice a direct operation of ECHO - ECHO Belgrade was responsible for the distribution of the parcels -, the funds were passed to an NGO which purchased the food parcels from a supplier without tendering. It was not until the fourteenth contract, in May 1994, that a competitive procedure was followed, and the supplier reduced the price of the supplies by 16 % and that of the transport by 37 % (59). In this case, the Commission should have been more active in ensuring proper competitive tendering from the outset;

b) in the case of supplies of seeds and agricultural tools to Angola, the way in which the ECHO staff issued a call for tenders made it impossible to make a valid comparison of the bids received, with the result that contracts were several times awarded to the same supplier. Where the size of contracts makes it necessary for performance to be spread over several months it is impossible for urgency to be cited as justification for direct negotiations. Discipline must be improved in this area.

4.27. Until the end of 1995, for emergency food aid financed from budget heading B7-211, ECHO was obliged to follow the mobilization rules laid down in Regulation No 2200/87. For all other procurement for its direct operations, e.g. in former Yugoslavia, ECHO was able to apply mobilization procedures which it managed itself. In this respect, the Commission should consider whether it would be expedient to set up a single procurement and tendering system for humanitarian and food aid, in which procurement expertise could be concentrated. Furthermore, emergency procurement procedures should be used only where situations of real urgency exist. Where direct operations are being implemented in situations of protracted emergencies, such as in Croatia and Serbia, normal procurement procedures can be applied.

Monitoring the progress of operations

4.28. Monitoring occurs at several levels. First, the implementing partners must monitor their own operations so that they can report back to the Commission and, if necessary, propose timely amendments to the action. In some cases, notably where the UN agencies and international organizations are involved, ECHO's partner subcontracts international or local NGOs to distribute the aid to the final beneficiary. A second level of monitoring by the agency or the international organization is thus involved. A third monitoring is that of ECHO itself, by technical assistants in the field or by headquarters' staff. ECHO's own monitoring role is particularly important in relation to its direct actions. An additional element in the monitoring process is the evaluation activity, whereby consultants, at ECHO's request, undertake on-the-spot evaluations of the action (see paragraphs 5.1-5.40). Usually these are organized before the end of the action, and so contain an important element of monitoring.

Direct operations

4.29. In its direct aid measures, and, more especially, the food aid operations in Croatia and, to a lesser extent, Serbia-Montenegro (60), the Commission was able to set up an efficient system of monitoring through the agency of its local representatives. The NGO teams of expatriate and local staff in Croatia were good and were relied on as a means of keeping the programme under control, despite strong pressure from national and local authorities and, even, on occasion, refugee communities. On this point, the UNHCR representative in Zagreb highlighted the exceptional reliability of the information gathered by the teams that had been financed by the Community. The monitoring teams engaged by the Commission to check the delivery of food aid supplied to Armenia, Azerbaijan and Georgia in 1994/95 played an important role in ensuring that the food reached its destination with minimum losses.

Operations carried out by partners

4.30. Senior management of the major UN agencies recognizes that as they rely more and more on NGOs as implementing partners, there is a need to review their practices and improve monitoring. This requires agreement between the agencies and the Commission on who is responsible for monitoring what. If an agency such as the WFP delivered humanitarian supplies to 'extended delivery points` (EDPs), after which other implementing partners or local organizations ensure final distribution to beneficiaries, the agency's own information systems are not geared to detailed reporting on distribution beyond the EDPs. Its monitoring at this level is restricted to what its field officers can do, otherwise it relies on reports supplied by the partners or local organizations. ECHO, however, expects the agencies to be able to report back fully a detailed distribution. The difficulties the agencies have had in doing this have contributed to the dissatisfaction expressed by the Commission with the performance of, for example, the WFP and the UNHCR (see Boxes 2 and 3).

4.31. Neither the WFP nor the UNHCR have their own resources to fund monitoring activities. If more intensive monitoring by the WFP and the UNHCR is required by the Commission, then it has to be taken from the grants allocated by the Commission. The example of the Croatia and Serbia direct food aid actions is illustrative in this regard (see paragraph 4.29). In large, extended crises such as former Yugoslavia, where the amounts of mobilized humanitarian aid are enormous, there is a need for the major actors such as ECHO, the UNHCR and the WFP to agree upon what monitoring is required and to fund it as a specific item.

4.32. Tracking large volumes of aid supplies through a distribution chain with many links and subdivisions is very complex and the large agencies do not have satisfactory systems for tracking commodity beyond EDPs (61). Developing and operating management information systems that generate accurate, reliable data is very difficult. The Commission and other donors should, however, continue to work with the large agencies on improving their systems.

Box 3 - European Union aid implemented by the World Food Programme (WFP)

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Whereas the WFP has, traditionally, been responsible for the food element of the United Nations' development aid, it has carried out an increasing proportion of the humanitarian operations in recent years. The European Union and its Member States are the WFP's leading source of funds.

With the increase in its humanitarian operations, the WFP is experiencing difficulty in covering its operating costs. These difficulties are associated with the management systems and operational procedures, which are not designed to keep accounts at the level of individual contributions from the programme's sponsors. They have recently occasioned comments by several donors, including the Commission. In this context, a multi-donor working party was set up in 1994, to develop the specifications for an information system that would be acceptable to all. As of the end of 1995 the working party had still not completed its work.

The Commission's concern is increased by the fact that, far more than for the other United Nations agencies, the visibility of the European Union gifts distributed by the WFP is relatively poor, because the trail is difficult to follow at grass-roots level (62). Moreover, the time taken to transfer the aid is relatively long and the estimates of requirements are often 'cautious', so that it is not always possible for the WFP to mobilize all the appropriations committed by the Commission and they then lapse in consequence. Finally, the level of incidental costs associated with each operation (63) is, in the Commission's opinion, high.

In the opinions of the WFP staff interviewed during the audit:

a) the framework partnership agreement prepared by ECHO did not allow the WFP to recover the full cost of its operations;

b) departments of the Commission imposed different accounting requirements as a function of their own individual procedures;

c) the duration of Commission financing was too short and poorly adapted to the length of operations.

In practice, the WFP's role of lead agency is confined to food aid. Only in Angola did it play an increased role, probably for historical reasons (64).

Despite a recent improvement in high-level relations between the Commission and the WFP, there are still practical difficulties which will not be overcome until all the parties have become fully conversant with each other's constraints and procedures. The audits carried out in the central and local offices of the WFP and the Commission showed that there had been misunderstanding on both sides, because of ignorance of their respective procedures. In this context the Commission should specify how it is to operate vis-à-vis the WFP (65) and should arrange for its local delegations to be closely involved in monitoring operations.>END OF GRAPHIC>

4.33. As far as operations implemented by NGOs are concerned, there is a widespread recognition amongst the major organizations of the need for rigorous self-monitoring both by field staff and headquarters, but performance remains variable. Inadequacies in initial preparation of projects, with poorly defined objectives and action programmes (see paragraph 3.13), make monitoring and reporting results difficult. The lack of definition by ECHO of what should be included in narrative reports is one reason why many narrative reports (more than 20 % of the 104 operations examined) provide little information about monitoring and what the project had achieved. Thus, even where there had been adequate monitoring, the reports did not show it.

4.34. The NGOs visited on the spot in Angola and former Yugoslavia were, in general, monitoring their projects closely and were able to present up-to-date information on implementation status. The situation at the headquarters of the NGOs visited was variable, with some having only a general idea of activities on the ground, whereas others had full details, and staff from headquarters visited the actions on the ground fairly frequently (62).

Monitoring by the Commission

4.35. ECHO relies to a large extent on its technical assistants in the field to monitor implementation by its partners (see paragraphs 4.8 and 4.9). Their effectiveness is varied: in Croatia and Serbia the technical assistants in the ECTF and ECHO Belgrade working with NGOs were experienced and well accepted. They were in frequent contact with the NGOs, visiting project sites, providing advice and assisting with new project proposals or changes to existing projects. They also participated in the coordination meetings with the UN agencies, NGOs and donors. In Angola, however, the situation was the opposite.

4.36. The UNHCR's 1994 programme (1,8 Mio ECU), which overlapped with that of other agencies (UNICEF), had to be recast on several occasions, owing to the resurgence of the war in Angola. A large part of the distribution of supplies and foodstuffs had been subcontracted to three NGOs which were operating in difficult areas - circumstances where particularly close follow-up appeared advisable. The work programme finally came to a halt part way through; it had not been possible to distribute a sizeable proportion of the supplies and the operations which had started did not have any lasting effect in two of the three provinces concerned. A large part of the funds paid to one of the NGOs had been used to refurbish three of its offices. The local ECHO agent had not monitored the operation in any way.

4.37. At the time of the Court's mission on the spot in 1994 and 1995, the role of ECHO's technical assistants needed clarification. Even in Zagreb and Belgrade the assistants had not been told how far they should go in seeking information and monitoring the partners, particularly the UN agencies. Their roles were not defined in the operational contracts with the partners, and their own terms of reference were general. They were not always consulted on new contracts arranged between the headquarters of the NGOs and the Commission, and sometimes were not even sent the contract until they requested it from Brussels. In addition, when ECHO was established, the previous practice was dropped whereby delegations were required to give short evaluations of the performance of a partner before final payments.

4.38. In March and June 1995, ECHO organized seminars in Nairobi and Moscow respectively for the technical assistants to address these issues, following which steps were taken to improve their terms of reference, working methods and reporting procedures. Together with measures being taken to improve contractual arrangements and the management of such technical assistants, these matters are being dealt with progressively.

4.39. The Commission should make more realistic evaluations of its requirements for technical assistants. In Serbia one technical assistant was responsible for monitoring ten NGOs and about 20 projects covering five sectors. Consultants engaged by ECHO to examine actions monitored by ECHO's technical assistants in Nairobi and in Azerbaijan pointed out that it was impossible for these technical assistants to do all that they needed to do.

4.40. The monitoring carried out by the Commission in Brussels of the substance of the actions is limited. Desk officers occasionally make on-the-spot visits to the NGOs and projects coming within their sphere of responsibility. Their back-to-office reports are often too general. In 49 of the 74 NGO contracts verified (63), the reports were insufficient to allow the Commission departments to appreciate adequately what the partner had actually achieved before making final payments. For example, final payments were made even though the narrative reports of the partners made it clear that the bulk of the commodities involved had not been distributed: once the final payments had been made, there was no further follow-up of the projects.

Financial implementation procedures

4.41. Since 1995, ECHO has significantly improved the quality of financial management of its operations by introducing standard procedures. In the beginning, staff shortages hampered the task of rationalizing administrative and financial procedures, which was carried out in order to enable the organization to cope with the increase in appropriations and the growing number of measures supported (see paragraph 4.4), and at a later stage the same task was also hampered by the fact that the accounting systems varied according to the source of the funds concerned (64). A special computer application was therefore developed for the financial monitoring of the contracts as a whole. When this application had proved to be inadequate, development of a new local application was started in September 1993. The latter was still not fully operational at the end of April 1996 and the reliability of the data which it provided was limited. In the circumstances, the financial departments are obliged to resort to specialized applications. The situation should be corrected, so as to eliminate the duplication of resources.

4.42. Article 24 of the general conditions of the framework partnership agreement allows ECHO to pay an advance of 50 % of the amount of each operational contract, at the partner's request. Additional advances are also possible, up to a limit of 80 % of the total budget for the measure. Many of the partners have complained about the delays in paying advances. Examination of some 30 contracts showed that the average interval after the signature of the contract had fallen from 56 days in 1993 to 36 days in 1994 and had risen to 46 days in 1995. In some cases the payment time was around only 12 days, which shows that improvements are possible. If the advance were paid automatically as soon as the partner returned the signed contract for the operation, the delays in paying advances would be reduced, without any loss of control.

4.43. A final financial report is required within three months of the end of every operation and, once it has been filed and accepted, the balance on the contract must be paid as soon as possible. On more than 50 % of the files examined the reports had been submitted late. The average time for payment of the balance was around 50 days in 1993, rose to 80 days in 1994 and was more than three months in 1995.

4.44. There are several causes of delay, including:

a) in some cases, the necessity of obtaining further information from the partner;

b) the time required for evaluation of narrative reports by desk officers;

c) the level of detail that has to be checked in the financial annexes before the account is finally settled. However, the main factor in lengthening delays is the steady increase in the number of projects (more than 1 000 in 1995) to be handled by the financial unit.

4.45. If the partner does not raise any objection within six weeks of the final payment, the file is closed, even if appropriations are still available against that operation. Up until 1994, the appropriations remained committed, and therefore ineffectual, for periods of more than a year. Since then, ECHO has tried to clear closed operations every quarter. In 1994 the average interval between final payment and cancellation of the balance of appropriations was around four months. In 1995 the interval varied between two and eight months. By the end of 1995, these operations to cancel balances had ceased to be systematic and, in the case of the EDF, were carried out only in situations where there was a shortage of appropriations.

4.46. The nature of humanitarian operations makes expenditure forecasting an arbitrary matter and it is not unusual for advances paid by the Commission to exceed actual expenditure. In these cases, ECHO is obliged to recover the surplus funds at the time of final settlement. Several months elapse between the winding-up of the file and the issue of a recovery order, even when the partner states that it is prepared to refund the amount quickly.

Conclusion

4.47. In view of the scale of recent crises and the absence of adequate redeployment of staff by the Commission, ECHO has been obliged to make extensive use of temporary staff (see paragraphs 4.4-4.7). The rules and practices regarding the conditions of recruitment and employment of the staff of Community institutions are ill-suited to the demands of humanitarian operations. The current rigidity of the system has a paralysing effect (see paragraphs 4.4-4.10).

4.48. The framework partnership agreement has proved to be a useful administrative tool. In its present form, however, it is of limited use for steering, controlling and monitoring the extent to which the partners contribute to the priorities and objectives adopted by the Commission and is not suited for all organizations (international organizations, large NGOs, small NGOs). For making the tool more effective, a differentiation of such contracts according to the different types of partners would be necessary (see paragraphs 4.17-4.21 and 1.3).

4.49. The evaluation of partners' procedures and management systems is an area in which ECHO must continue to make an effort.

4.50. In two cases involving consignments of foodstuffs and supplies the procurement procedures were defective. In the case of family packages, the sums which could have been charged to the Commission unduly may have amounted to several million ecus (see paragraph 4.26).

4.51. Whereas ECHO scrupulously verifies the financial accounts when settling expenditure, evaluation of the actual implementation of work programmes and the results obtained by its partners were subject only to limited checks, even when the reports submitted were extremely terse or vague (see paragraphs 4.28-4.34 and 4.40).

4.52. Irrespective of whether operations were carried out by large international organizations or NGOs, on-the-spot monitoring by Commission staff still needs to be improved. The monitoring of current operations and the results actually obtained is a high-risk area, and the Commission must devote more attention to it. If, in accordance with the mandate given to ECHO, the Commission wishes t