NABU's Audit: we'll evaluate what's working well, what isn't, and offer recommendations

Along with my colleagues and fellow audit commissioners Martin Arpo and Hermione Cronje, we have begun the external audit of NABU. This is the first such evaluation since NABU’s establishment in 2015. As such, I would like to share our vision regarding the goals, process, challenges, approach, current status, and next steps of this important engagement.

Let’s start with the goal: We are here to independently assess NABU’s performance. Is NABU meeting expectations and what can be done to improve its effectiveness?

We will evaluate NABU’s effectiveness from March 6, 2023 (when the current NABU director was appointed), up to November 18, 2024 (the date our commission approved its methodology for conducting the audit).

The aim of this audit is to provide the Ukrainian people with a clear assessment of NABU’s current standing and produce a report that will serve as a guide for future improvements.  Our focus is on objective findings and actionable recommendations for enhancing processes rather than simply assigning labels of success or failure.

While we will address weaknesses in institutional processes, it is crucial to differentiate between the dedicated public servants at NABU, who tirelessly combat corruption, and the organization as a whole. We are committed to viewing the processes objectively from an external perspective to create a roadmap for institutional development.

Conducting an external audit reflects Ukraine's serious commitment to anti-corruption efforts at this critical moment in history. This commitment is recognized by Ukraine’s international partners, as this audit represents a significant structural benchmark for Ukraine in the 2024 Memorandum with the IMF. The Commission was engaged by the Ukrainian government based on its determination to establishing a robust anti-corruption system, and we are dedicated to supporting Ukraine in this endeavor.

Audit can mean different things to different people. When some people think of an audit, they think of a financial audit, which assesses financial reports and accounts. Others may think of a compliance audit, which assesses whether an organization is following some standard and often is presented in a "yes/no" format. Measuring the degree of effectiveness, though, is a more complicated matter and more closely resembles what’s called a performance audit. We auditors identified a relevant benchmark and will measure NABU’s performance against that benchmark. In this case, we will be assessing whether NABU processes are aligned with international best practices. 

The strength of this Commission lies not only in our external expertise but also in the extensive local experience within our team. This combination of international expertise and local insights through the Secretariat is vital. Both perspectives will be essential for conducting a thorough independent external audit.

Our vision how to measure the effectiveness of an anti-corruption agency

The task at hand is highly complex. As this is the first audit, we needed to identify objective criteria and develop a methodology from scratch to evaluate NABU’s effectiveness over a period of more than 1,5 years. Defining objective criteria to measure effectiveness, especially for an organization like NABU, presents significant challenges as there is no uniform, internationally accepted list of benchmarks to measure the effectiveness of an anti-corruption agency.

We are committed to a systematic, evidence-based approach which will ask the right questions, identify the right evidence, and provide the right insights, and a roadmap for improvement. Our aim is to be tough, but fair.

In developing the criteria and methodology, we based our approach on international standards and good practices in government performance auditing and evaluation, and by using anti-corruption standards and principles from various international instruments. In October, we conducted our first mission in Kyiv, holding consultative meetings with NABU and other key anti-corruption stakeholders in Ukraine. We also hosted a listening forum with civil society organizations to gather their perspectives. We initiated the information-gathering process from NABU and we used this information to finalize our methodology.

We have identified five dimensions of effectiveness for an anti-corruption investigative agency like NABU: Detecting and Investigating High-Level Corruption; Integrity, Accountability and Transparency; Leadership, Strategy, and Resource Management; Interagency Coordination; and International Cooperation. These dimensions are based on international standards and principles from a number of sources identified in our methodology document. There are certain essential principles  that affect NABU’s effectiveness—such as institutional and organizational independence—that permeate all dimensions and will be evaluated across all five dimensions.

To evaluate NABU’s effectiveness, we developed a weighted rating model that will enable us to conclude whether NABU’s performance in each dimension and overall has been highly effective, substantially effective, moderately effective, or ineffective. Detecting and Investigative Corruption is NABU’s core activity and is accordingly given a higher weight. The dimension of Integrity, Accountability and Transparency is also given a higher weight, as NABU must hold itself to the highest standards to be a credible and trusted watchdog.

I understand that the issue of leaks of law enforcement information is a significant concern for Ukrainian society. I want to assure you that we will be evaluating the protection of sensitive investigative and operational information, as well as guarantees for whistleblowers.

Recently we approved and published the methodology and criteria, which includes comprehensive details about our evaluation approach, principles, processes, evaluation key indicators, and the steps we will take to reach our conclusions. You can find that document at the official page of the Commission.

We will soon be back in Kyiv to gather evidence, and we expect to complete our final report this spring.

Before I get back to work, let me assure you that our audit will provide a thorough and objective evaluation of NABU’s effectiveness, offering actionable recommendations to enhance its anti-corruption efforts and support Ukraine's commitment to a robust institutional framework. We encourage you to stay tuned as we share updates on our progress and findings throughout this important journey.