Transparency Maldives (TM) notes with grave concern the increasing trend of undermining democratic practices and institutions by the State including the recent move to reduce the number of judges in the Supreme Court; the sudden removal of the Auditor General by the parliament; and the resolution  of the opposition Maldivian Democratic Party (MDP) calling to handover the presidency to Jumhooree Party (JP) leader Hon. Gasim Ibrahim.

Amendment to the Judicature Act and reducing the number of judges

TM fears that the recent amendment to the Judicature Act to reduce the number of judges from 7 to 5 followed by the recommendation by the Judicial Service Commission (JSC) to remove two sitting Justices will further undermine the independence of the judiciary.

The impartiality and independence of the Supreme Court (SC) is not solely decided by the number of Supreme Court Justices but rather by the upholding of judicial integrity and principles. Any move to reform the judiciary must be sincere and look at the entire judicial system, especially the judicial watchdog body, JSC, so that meaningful and real reform may take place.

The decision by the JSC to remove Chief Justice Abdulla Faiz and Justice Muthasim Adnan without publicising the criteria against which they were evaluated raises questions about the transparency and fairness of the process. The criteria used must be objective, based on merit, transparent and well-publicised so that any public concerns about the process may be addressed. TM also notes that the amendments to the Judicature Act allows JSC to override due procedure denying the right of Supreme Court Justices to defend themselves before their dismissal. TM calls on state authorities to refrain from any action that will further undermine the independence and integrity of the judiciary.

Amendment to the Audit Act and removal of the Auditor General

TM notes that the recent amendment to the Audit Act which abruptly ended the tenure of the sitting Auditor General, before the Constitutionally mandated seven-year term serves to undermine the independence of the Auditor General’s Office. Furthermore, the amendment circumvents Article 218 of the Constitution, which prescribes that the only grounds for removal of the Auditor General before the end of his term are misconduct, incapacity or incompetence. It must be noted that the passing of the amendment and the consequent removal of the Auditor General coincided with the release of an incriminating audit report against a Government Minister. TM calls on state authorities to ensure that heads of independent state institutions are given the autonomy to do their mandated work free from insecurity.

Decree by MDP on transferring power to JP leader

TM condemns the resolution passed by the opposition, Maldivian Democratic Party (MDP), calling to handover the presidency to the leader of Jumhooree Party, Hon. Ibrahim Gasim, in the midst of the water crisis, as it attempts to destabilize the elected government and infers overriding the electoral processes stipulated in the Constitution. TM reminds that any change in government should only be brought by a vote of the people and calls on state parties to not undermine the electoral processes of the country.

TM calls on all organs of the state, including political parties, to uphold, respect and operate within the boundaries of the Constitution, and democratic norms and principles.

ENDS

For media queries, please contact Advocacy and Communications Manager, Aiman Rasheed (790 8967).

View/download the statement in English and Dhivehi.


I applied to Transparency Maldives for an internship because I wanted to do something meaningful during my time back home for summer break from university studies. It proved to be an invaluable experience that helped to broaden my skill set and improve my understanding of the contemporary sociopolitical issues in the Maldives. The experience would not have been the same without my colleagues who were supportive and challenged me to get the most out of the internship.

Symposium on Freedom of Association

I did an array of different work during my three month internship at TM. I was able to improve my administrative skills by assisting to arrange advocacy stakeholder meetings undertaken to review the Association Act. I also did research based tasks such as heading a volunteer team to conduct interviews with Women’s Development Committees; and later in analyzing data.The highlight of my internship would probably be travelling with TM to conduct civic education workshops in Thaa atoll. This provided me with the chance to meet a lot of interesting people and in return learn from them as well. Towards the end of my internship I assisted in organizing the ‘Symposium on Freedom of Association’ which was challenging and at the same time very inspirational. Through my internship I gained valuable insight into how a civil society organisation engages at both policy level and grassroots level.

Aminath Saany Naseer
Civic Participation Project


Interning for Transparency Maldives for two months during university holidays allowed me to improve my skills and gain experience at an organization making a significant impact in our society. Although I expected my time in TM to be a lot of paperwork and filing cabinets (as per all intern jobs) I was quickly proven wrong by a very supportive team around whom it was hard to feel like an intern; I not only felt like I was being listened to, but that what I said made an impact in the project. Throughout my entire time with Transparency Maldives, I was given engaging and meaningful work that made me feel like I was not only learning, but actively contributing to the organization’s goals.


Commonwealth Human Rights Initiative Right to Information Conference 2014, held in Kurumba Maldives


Sara facilitated a Democracy Talks session for students in Addu Atoll Education Centre

My time in TM coincided with a series of Monitoring and Evaluation trips around Maldives, and I was excited to accompany the team on two of them: to S.Meedhoo and Gn.Fuvahmulah. Both of the trips were an opportunity to learn about a more practical hands-on side of the work TM does and of course, a much deserved break from the office! The trips gave me crucial knowledge into how community projects and nonprofit organizations worked. I particularly enjoyed co-facilitating Democracy Talks in the schools as it was a chance to engage with the children and raise awareness about positive citizens and democracy.The chance to help in the organization of an international symposium on the Right to Information towards the end of my internship was definitely the highlight of my time in TM. Overseeing the logistical details of the conference was particularly demanding, educational and rewarding.

Sara Naseem
Civic Participation Project Intern


Transparency Maldives is organising a poster competition themed “Corruption Robs Us All” to commemorate the International Anti-Corruption Day – 9th December 2014.

You should articulate and draw attention to corruption and its detrimental affects on people on their everyday life. You can focus on separate sectors (e.g. youth, women, health, education, housing, etc) or on development generally.
Who can take part in the Competition?
  • The competition is open for everyone.
How to submit your poster: 
  • You must send in your posters with entry form on or before 30th November 2014 by 5:00pm, to the following address:
                                        Transparency Maldives
                                        7th Floor, MF Building
                                        Chandhanee Magu
                                        Male’, Maldives
For more information, call 300 4017 or mail to alac@transparencymaldives.org
What are the rules of the Competition?
  • Posters must incorporate creative and original artwork and ideas. Depictions of cartoon, video game, and movie/television characters; celebrities; movie themes; and past poster designs do not constitute creativity and originality;
  • Posters must be no larger than A2 (59.4 X 42 cm) and no smaller than A4 (29.7 X 21 cm).
  • You should refrain from writing your name or other identifying information on the front of your poster;
  • Your poster can be designed using illustration, photography, typography, mixed media or any graphic design technique you choose.
  • Avoid using any copyrighted or trademarked materials or objects as elements of your design. Computer clip art, pictures from magazines and other print media, or any other copyrighted brand or product images will not be accepted;
  • By submitting a poster, participants give permission for their work to be displayed at various Transparency Maldives events, in publications and promotional material, and in electronic format on the internet;
  • Failure to comply with the guidelines could result in a disqualification of the poster.
  • Scanned files should be not more than 5MB and not less than 1MB.
Selection and Prize:
  • The posters will be judged based on the following criteria
1. Relation to the theme – 30%
2. Artistry – 10%
3. Creativity – 20%
4. Originality – 10%
5. Ability to communicate a clear and positive message – 30%
  • The winning entries shall receive the following prize:
                                     First prize: MVR 7,000
                                     Second Prize: MVR 4,000
                                     Third Prize: MVR 2,500
  • Selected posters will be displayed at an exhibition to commemorate the 2014 Anti-Corruption Day.

 


Transparency Maldives’ (TM) survey, Democracy at the Crossroads, points to a crisis of public confidence in key democratic institutions. Citizens are cynical. Politicians, they think, lie to get elected and they don’t believe that the government cares about ordinary people.
The nationwide survey aims to encourage informed debate of democratic norms and about the performance of democratic institutions.
“This [the survey] shows that citizens are less likely to meaningfully participate in public matters and in holding public officials accountable. If so, it will ultimately lead to impunity and corruption,” Mariyam Shiuna, Executive Director of TM said.

Crisis of confidence

Citizens lack confidence in their key representative institutions. 62% of survey respondents say they have no confidence at all in the parliament. And 58% have no confidence in political parties. 50% and 46% citizens lack confidence in local governments and courts respectively. These results are similar to TM’s Global Corruption Barometer surveys from 2012 and 2013.
77% of Maldivians identify “politics,” which includes conflict, corruption and the party system, as the most important problem facing the country. Half of the public is dissatisfied with the way democracy operates in the Maldives.
Maldivians give political leaders a low rating. None rate better than average.

Cynicism, democratic values and social order

86% of Maldivians say that the government does not care about ordinary people and 92% of Maldivians believe that politicians are “ready to lie to get elected”, showing extraordinarily high levels of cynicism in comparison to similar transitional democracies.
Citizens are critical of the social order: 84% think that power is concentrated in the hands of too few people.  The good news is that 90% of the public believe dialogue is the way to solve the country’s problems. The bad news is that 1 in 3 think that violence is sometimes a necessary response to social injustice.
Maldivians are not enthusiastic about gender equality. A majority think men make better leaders than women. Remarkably, more women than men support the idea that men make better leaders than women.

Is there hope?

“Democratic institutions must take extraordinary measures to regain the trust of the public and the public must step up to hold public officials to account,” said Aiman Rasheed, Advocacy and Communications Manager. “Levels of confidence in institutions is a key indicator of the levels of corruption in a system,” he added.
This is the first systematic survey on democracy conducted in the Maldives and provides important benchmark data. The random sample of approximately 1,000 citizens provides a margin of error of +/- 3.0% and the findings are generalisable to the entire country. The questions asked come from surveys that have been repeatedly used and tested around the world.
ENDS
For all media queries, please contact Advocacy and Communications Manager, Aiman Rasheed (00 960 7908967).

Click to view/download the report ‘Democracy at the Crossroads’ 

Click to view/download this statement in Dhivehi
Click to view/download this statement in English


_URI0619jpg
Desperate for money migrant workers do additional odd jobs to meet their basic needs. With no assistance in addressing their issues, workers are left to fend for themselves.

A group of construction workers working for a company based in the Maldives were denied their monthly salaries for 8 months. They finally stopped working and asked the company to pay them what they were owed and make arrangements for them to return back to their country. However, the company turned down their request.

Desperate and without any money to even meet their basic daily needs, the group approached the Indian High Commission in Maldives for help.

When the High Commission failed to assist them, they approached our legal advice centre for help. We contacted the company on their behalf and after several discussions, the company agreed to pay the group their due salaries and make arrangements for them to return home to India.

_URI0415jpg

‘The advocacy and legal aid centre helped us to get our unpaid salaries and negotiated with our company to send us back to India. Before coming to the legal aid centre we also went to Labor Relations Authority and the Indian High Commission. But it all became possible because of the work of the legal aid centre. We are really thankful for the help.’


The estimated official figure of migrant population in Maldives is 140,000. The unofficial estimates are above 200,000 bringing the size of the migrant population in Maldives up to almost two thirds of the total Maldivian population of the country.

_URI8112jpg
Migrant workers collect garbage from households daily for a small monthly fee.

Regardless of this figure, migrant workers have few rights and state redress mechanisms are not accessible to these workers, further victimizing those who are already being exploited in forced labor conditions. The language barrier and the lack of public interest litigators in the country further limits their access to the justice system. Maldives has been ranked in the Tier Two of the US State Department’s Watch List for Human Trafficking for the fourth year in a row.

Migrant workers often sell all their assets to come to the Maldives and are reliant on their new employers for sustenance for themselves and their families back at home. Often times, they face threats or even violence for speaking up about injustices. Their living quarters are generally provided by their employers, so if they are dismissed they also lose their housing. The majority of the cases that Transparency Maldives’ free legal advice center receives from migrant workers include complaints of non-payment of wages, often for months, withholding of travel documents and identification and inhumane living conditions.

_URI3551jpg
Migrant workers sort and collect garbage in Thilafushi, an island fully reclaimed by dumping garbage into a lagoon. They endure toxic smoke and a hazardously polluted environment daily.

Migrant workers live and work in unimaginable conditions, sometimes being forced to do work that is not permitted in their work permits. They are underpaid or unpaid, their passports and identification documents withheld by agents and employers, effectively crippling workers from rectifying their situation or reaching out to the justice system.Our advocacy and legal aid center provides free legal advice and assistance to expatriates and Maldivian citizens. We have assisted over 560 migrant workers with cases of non-payment of wages, unacceptable working conditions, poor housing, withholding of their passport by employment agencies and employers, and being forced to do work that is not permitted as per their work permit.

These are not newly emerging issues and they closely reflect the findings reported in U.S Department of State’s Trafficking in Persons Report (June 2013). The report notes fraudulent recruitment, confiscation of identity and travel documents, withholding or non-payment of wages, or debt bondages as some of the forced labor situations faced by the migrant workers in Maldives.

While the necessary regulations such as Regulation on Expatriates Working in Maldives and Regulation on Bringing Expatriates to the Maldives for the purpose of Employment are in place, the issues arise from the lack of implementation, monitoring and enforcement of said regulations. With the Anti-Human Trafficking legislation that was ratified in December, 2013 withholding passports or identification and forms of exploitation of migrant workers has been criminalized.

We encourage exploited workers who need legal assistance and advice to come to us. Corruption and human trafficking are inter-related. Human trafficking often happens due to systemic governance failures, often caused by corruption. The cases and complaints submitted to our advocacy and legal aid centre shed light on the linkages between the two issues. Corruption and human trafficking are two sides of the same coin and need to be addressed as a matter of urgency, to prevent further abuse of workers rights.


A group of Bangladeshi laborers employed by a Maldivian company approached our advocacy and legal aid centre with their grievances. A story that reflects the condition of many other migrant workers like them in the Maldives. They were ill-treated, stripped of their basic rights and forced to work for 13 hours a day. They worked without resistance because they feared losing their only source of income to support them and their family back in Bangladesh.


Migrant workers often do physically straining odd jobs in addition to their day jobs to make ends meet.

Migrant workers in Maldives live in unhygienic and cramped conditions. It is the norm for 50 or more workers to sleep in 8 hours shifts in 20 x 10 ft spaces.

For six months, they received no payment. They went to their employer repeatedly, explaining that they need the money to feed themselves and their families. Their employer refused to pay them, telling them that the company is struggling financially.

They filed a complaint against the company at the Labor Relations Authority and were met with vengeance. As punishment employer cut the electricity from their living quarters.

Desperate and fearful, they came to our advocacy and legal aid centre. We wrote to the Human Rights Commission of the Maldives explaining the situation and asking if a solution could be found.

Our intervention led to a positive outcome and helped solve their immediate problems. Electricity in their living quarters was restored within 24 hours of complaining to the Human Rights Commission.
The case is under investigation by HRCM. At our advocacy and legal aid centre, we are monitoring the situation to ensure that they get their due wages paid to them in full.


PRELIMINARY STATEMENT
MALE — (23 March 2014) — Transparency Maldives (TM) appreciates and thanks all observers and volunteers in our observer network, based in 20 atolls and Colombo and Kuala Lumpur. The observers were key to the success of the observation. TM hopes that an independent observation effort at this scale has instilled greater levels of trust  in our electoral processes. The results we report are based on random sampling and are generalisable to the entire country.

1. Polling day
The election day processes were transparent and generally well-administered. We are happy to report that the election has been peaceful with just one reported incident of violence inside a polling station. TM congratulates Maldivian citizens for their spirited engagement in the democratic process.

The following are the key findings which we would like to highlight from our observation. 83.52% of polling stations closed within the first hour of the normal closing time of 4:00 p.m.

Voter registry was overall very clean, with a very few cases where people were not able to vote because their names were not on the voter registry or their details did not match. Assisted voters were spread across 84.1% of the polling stations.

Voting was temporarily halted in 2.4% of polling stations. 75% of these cases were interventions at the direction of the Presiding Officer while 25% were interventions by an unruly voter.

We note that the police entered 12.35% of polling stations. However, in 100% of such cases, interventions occurred at the invitation of the Presiding Officer as the rules allow.

Candidates were well-represented during the counting, making the process transparent and adding to its credibility. Maldivian Democratic Party was represented at 89.4% of polling stations during the vote count. Coalition parties were represented at 88.8% of polling stations during the vote count. Only 5.9% of polling stations did not have a party/candidate observer present at the opening of the polls.

Unresolved disputes were reported at only 5.3% ballot boxes at the time of announcing results.

However, TM calls on all actors to take immediate measures to address wider issues, including vote buying, lack of transparency in political finance, abuse of state resources, barriers for women’s equal participation in the electoral processes, and bring long overdue reforms to the electoral legal framework.

2. Vote buying
In a survey conducted by TM in the run up to 2013 presidential elections, 15% of respondents reported that money or other incentives were offered in exchange for their vote. Admissions about illegal activities such as this are usually underreported in surveys. TM’s long-term observation indicates that vote buying may be even more widespread in the parliamentary elections than other elections.

Inability of state institutions to prosecute vote buying due to gaps in the electoral legal framework, lack of coordination, and buck-passing between the relevant institutions have allowed rampant vote buying to go unchecked.

TM recommends to all relevant institutions to monitor, investigate and prosecute vote buying through implementation of the existing legal provisions and recommends to the Parliament to bring urgent reforms to the laws to better address the issue.

3. Lack of Political and Campaign Finance Transparency
Deep flaws in the standards, practices and poor oversight have led to the lack of transparency in political and campaign financing in elections, including the parliamentary elections. When political parties and individual candidates do not fully disclose where they get their money from, it is not clear who funds them, what their potential conflict of interests are, and, thereby allows vested interests to override public interest when elected as MPs.  Similarly, Transparency International’s Global Corruption Barometer surveys for the Maldives continue to indicate a crisis of public trust in the Parliament. Increasing campaign financing transparency in parliamentary elections is crucial to hold parliamentarians to account, in order to prevent the hijack of the institution by vested interests and regain public trust in the Parliament .

TM recommends addressing the gaps in the electoral legal framework and implementation of existing provisions to facilitate public scrutiny, ensure periodic reporting and an effective oversight mechanism for political finance.

4. Women Political Participation
Only 23 women out of 302 candidates contested the Parliamentary Elections, out of which only five were elected according to the provisional results. The Maldives is currently ranked 129th place in the Inter-Parliamentary Union’s index of parliaments in terms of gender balance. Relevant authorities should identify and address the barriers for women’s equal political participation.

5. Other Issues
Additional issues that need to be addressed are:

  1. Abuse of state resources and authority by successive regimes, allowing those in power to campaign at the expense of the public purse;
  2. Constituency delineation legal framework and processes that result in assignation of voters to constituencies not based on their domiciled residencies, robbing voters of effective representation;
  3. Instances where secrecy of the ballot  may be compromised when a few people are registered to outside their constituencies (for example, 2,947 cases of single voters; 1,070 cases of two voters; and, 502 cases of three voters);
  4. Lack of effective  long-term voter and civic education on issues such as vote buying, political finance transparency and equality of women in political participation; and,
  5. Uncertainties arising from the role of the judiciary in elections and, in particular, the 16-point guideline issued by the Supreme Court. TM reiterates that the guideline does  not improve upon the technical aspects of the election and recommends that any concerns the guideline intends to tackle be addressed through legislative reforms and within constitutional boundaries.

Transparency Maldives congratulates all winning candidates and urges all relevant actors to reform the electoral systems to increase confidence in and improve electoral systems in the Maldives. A final report on the findings with recommendations will be published within a month of conclusion of elections.

ENDS

For media queries, please contact Advocacy and Communications Manager, Aiman Rasheed on 00 960 790 8967.

Click to view/download this statement in English
Click to view/download this statement in Dhivehi


PRESS RELEASE 

Male – (22 March 2014) –Transparency Maldives thanks our observers deployed across the country for their dedication in observing the election processes. Transparency Maldives’ observer network has a wide national coverage spanning resorts, prisons, and abroad in Kuala Lumpur and Colombo.

The results we report are based on random sampling and are generalisable to the entire country. These results are based on the observation at the time of opening of polls.

The opening of the polls was smooth, and the administrative preparation went well. 79% of all polling stations opened by 8.10am, 20% of polling stations opened within the first hour of the required opening time, and 1% of polling stations opened between 9am and 10am.

Nearly all polling station officials were in place at all polling stations.

The materials required for voting were present and the ballot papers were counted at 100% of the polling stations. 100% of ballot boxes were verified as empty at the opening of the polls.

Candidates were well represented at polling stations. Only 10% of the polling stations did not have a party/candidate observer present at the opening of the polls. Maldivian Democratic Party (MDP) observers were present at 78% of polling stations while 81% of polling stations had observers from the coalition parties, at the opening of the polls.

Transparency Maldives also notes that police presence was visible at 93% of the observed polling stations at the time of opening.

Observers concluded that the polling stations were set up to ensure a secret vote in 98% of polling stations. Transparency Maldives observers will be closely monitoring the 2% of the polling station where the secrecy of the ballot may be compromised due to the layout of the polling station.

We encourage all parties to maintain the climate of peace. Our observers are working hard at polling stations and will be present at the polling stations until the polls are closed and the results are announced.

ENDS

For all media queries, please contact Advocacy and Communications Manager, Aiman Rasheed (00 960 7908967)

Click to view/download this statement in English
Click to view/download this statement in Dhivehi


TM’s Civic Participation Project team recently conducted civic forums in Lh. Naifaru, Gn. Fuvahmulah and S. Hulhumeedhoo. CBOs from the three islands were recruited to partner with TM, to conduct civic education workshops followed by a ‘Rayyinthunge Bahdhaluvun’ or the civic forum.

This pilot program was designed to increase civic participation with respect to increasing citizens’ willingness and ability to engage in political processes, thereby contributing to holding public officials to account and tackling corruption at community level.

Rayyithunge Bahdhalvun - Hulhumeedhoo Addu City
Rayyithunge Bahdhalvun – Hulhumeedhoo, Addu City

Citizen engagement in these civic forums, designed similar to town-hall style meetings, provided citizens a platform to engage in community affairs and apply democratic principles to address community issues.

In the three target islands, the civic education workshop and the civic forum was attended by police staff, members of Women’s Development Committees (WDCs), Councils, NGOs, health centers, schools and local leaders and political affiliates. Following a community issues identifying exercise the key issues facing these communities include the problem of drug abuse facing a large majority of youth, unemployment, and waste and sanitation issues.

At the civic forums, participants voiced the need for more public meetings and avenues for such similar public discussions in the future.

The civic education workshops and civic forums are supported by the International Foundation of Electoral Systems (IFES) and  funded by the United States Agency for International Development (USAID).


The lack of knowledge in the fast evolving landscape of global climate finance was evident in recent public sessions organized by Transparency Maldives, despite the image of Maldives as the poster child of climate change impacts in the global media. These sessions were held to increase participation of the general public in an e-learning course that was developed by Transparency International, with the purpose of spreading awareness of corruption risks in climate finance. The online course, designed for the general public, can be completed at the individual’s own pace.

Transparency Maldives conducted four sessions in December 2013 to guide interested participants through the course. The sessions allowed discussions, exchange of knowledge and opinions. Participants were given information on the main findings from the recent research by Transparency Maldives on climate finance issues in the Maldives.

Participants of Youth Leadership Programme of 2013
Participants of Youth Leadership Programme of 2013

Special invitations were also extended to the students of BSc in Environmental Sciences at the Maldives National University, staff of relevant government offices and participants of the Youth Leadership Program, organized by Democracy House, a local NGO. A total of 33 participants participated in four sessions held in December 2013. An additional 29 persons had signed up for the e-learning course directly.

Student of BSc in Environmental Sciences Maldives National University The course builds on technical knowledge of the students to complement practical challenges of implementation
Student of BSc in Environmental Sciences, Maldives National University. The course builds on technical knowledge of the students to complement practical challenges of implementation

The structure of the course and its presentation helped participants from diverse backgrounds and levels of technical knowledge, follow the discussions and complete the course.

Commenting on the main take-away of the course, Malaka Abdul Hameed, Senior Planning Officer of the Ministry of Tourism said, “I learnt a lot about the different forms of corruption and how it impacts climate finance governance.

”The course contains three modules. The first module is an Introduction to Climate Finance.This contains a brief background to causes and impacts of climate change and how different countries respond. The module then goes on to explore the sources of climate finance and how these funds are currently channeled to the affected countries.

The mix of graduate students and government staff allowed lively discussions and exchange of experiences
The mix of graduate students and government staff allowed lively discussions and exchange of experiences

The second is Corruption Risks and Solutions. It includes introduction to types of corruption and provides real stories of how climate finance has been affected by corruption.

This combination of topics makes the course useful for those who are learning about the issues, working in implementing or monitoring these projects, or those interested in ensuring climate sustainability.

In my opinion, the biggest challenge to ensuring climate finance transparency, is the lack of availability of relevant information,” Haleemath Layan Abdulla, aged 16, a participant of the e-learning course said.

The course also includes a discussion forum, where participants may network, post comments and thoughts on the issues covered.

The course is available to any interested person to sign up.  Please contact TM if you have any queries or wish to organize sessions.

The course was developed as part of the Climate Finance Integrity Program, a research and advocacy program conducted by 6 chapters and TI-S to assess risks to Climate Finance. The CFIP program was funded by the German Ministry of Environment.