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EVIDENCE SUBMISSION BY REPRIEVE TO THE INTERNATIONAL DEVELOPMENT COMMITTEE’S INQUIRY INTO THE DEFINITION AND ADMINISTRATION OF OVERSEAS DEVELOPMENT AID

 

             

Reprieve is an international human rights organisation which seeks to uphold the rule of law and the rights of individuals around the world. We provide free legal and investigative support to some of the world’s most vulnerable people: those facing execution, and those victimised by states’ abusive counter-terrorism policies – rendition, torture, illegal detention and extrajudicial killing.

             

 

EXECUTIVE SUMMARY

 

  1. The Conflict, Stability, and Security Fund (CSSF) is an £1 billion fund[1] used by the UK Government to finance programmes in areas of conflict and instability. The significant majority of this spending remains unpublished, and there is significant evidence that some of this money has gone to foreign security forces who are engaged in grave abuses of human rights.
  2. Despite attempts by Government to respond to criticisms made by Parliament, the public still knows too little about this spending and the risks remain high. New research by Reprieve reveals that more than two thirds of the money distributed through the CSSF remains unaccounted-for, and that significant sums have been sent to abusive security forces in countries like Bahrain and Ethiopia.
  3. The fund has already faced heavy criticism from Parliament’s Joint Committee on the National Security Strategy (JCNSS), which acknowledged serious human rights risks of some CSSF programmes, while warning that there remains so little information about the money that Parliament cannot do its job of holding the Government to account.
  4. While the Committee’s recommendations still have yet to be implemented by Government, the Independent Commission for Aid Impact (ICAI) has made further serious criticisms of the Fund. As they found, “there is little reliable data on whether projects are achieving their intended results or delivering value for money”, and the “absence of results monitoring [that] means that the Fund does not know if it might cause unintended harm”.[2]
  5. We still know too little about the programmes the CSSF is funding, and how the Government ensures it is being used safely. The Government should urgently provide Parliament and the public the information they need to answer these questions, and make the CSSF transparent, accountable, and safe.

CSSF SPENDING RISKS ENABLING ABUSES

  1. Inadequate safeguards on CSSF assistance to foreign security bodies risk actively enabling human rights abuses around the world. Without effective oversight of such assistance, taxpayers’ money may end up funding security forces accused of human rights violations or financing the imposition of the death penalty.
  2. By its very nature, CSSF spending involves significant risks to human rights – with the majority of even its published programmes involving the training or assisting foreign security forces, presenting other significant human rights implications.[3] Experts giving evidence to the JCNSS – which heavily criticised the fund earlier this year – have made these risks apparent:

“…the famous Petraeus surge in Iraq in 2006-07…was essentially CSSF on steroids, because special forces were involved as well. At any one moment, the leadership in the US embassy in Baghdad could cut a political deal, do some development and kill someone. That was a great fusion…”[4]

  1. In fact, another expert on the CSSF told the Committee that the Government would need to accept the risk that funding may “be linked to groups that may carry out human rights abuses” – since by eliminating that risk, “you have much less effect”.[5]
  2. In respect of Bahrain – a country in which torture, forced ‘confessions’, and other abuses are widespread – Reprieve has documented the UK’s provision of substantial assistance to the Bahraini Government through the use of CSSF funding – over the course of which the human rights situation in Bahrain has not only failed to improve, but may have worsened.[6]
  3. The FCO, for example, has provided training to hundreds of prison guards at the notorious Jau Prison, where Reprieve beneficiary, Mohamed Ramadan, faces execution for a crime to which he was forced to confess under torture.[7] Northern Ireland Co-operation Overseas (NI-CO) – a state-owned Belfast business – received almost a million pounds in UK taxpayer money in 2015 for work with Bahrain’s Ministry of Interior, and more than a dozen NI-CO experts worked with Bahrain’s prison staff at jails where systematic torture took place. As many as 400 guards at Jau Prison – where individuals on death row are held, and torture is routinely alleged – were trained under this programme, funded by CSSF money.
  4. In another example, a CSSF project provided £400,000 for a ‘Public Order’ project, despite increasingly Draconian bans on public protest in the capital, Manama, and an intensifying crackdown on legitimate dissent, including several killings of protestors just this year.[8] In addition, the FCO funded training for Bahraini police in “community intelligence” to be used ahead of protests,[9] along with “Combined Operational Training with a Focus on Public Order”[10] – training used by the Bahrain regime to further violate rights, and funded by CSSF money.
  5. The CSSF has also funded the work of an Ombudsman for the Bahraini prison system that has repeatedly declined to investigate torture allegations and false confessions leading to the death penalty. In one case, this Ombudsman appears to have deliberately misled the FCO as to the existence of one victim’s complaint so as to avoid investigating the allegations of torture and false confession, and later investigated his wife for ‘conspiring with foreign NGOs’.[11]
  6. CSSF money has also funded support for abusive security forces in Ethiopia, a country which Human Rights Watch judges to be in a “pervasive human rights crisis”, with “atrocities committed by security forces to suppress peaceful protests and independent dissent”.[12] Last year, the UN called on the Ethiopian Government – who still refuse to allow access to UN investigators – “to end the ongoing crackdown on peaceful protests by the country’s security forces”, who reportedly killed “more than 140 demonstrators and arrested scores more” over a nine-week period.[13]
  7. Using CSSF money, the UK Government has funded a ‘Training Centre’ and a course in ‘Security Sector Management’, overseen by Cranfield University and the Ministry of Defence, and a military training centre in Addis Ababa, run by the Ethiopian army – which 90% of senior Ethiopian intelligence officials have reportedly taken.[14]
  8. The UK Government is also using CSSF funds to train security forces accused of committing ongoing and serious human rights violations, and who are responsible for the kidnapping and rendition of a British citizen, Andargachew ‘Andy’ Tsege, to death row.[15] In fact, the Department for International Development had previously funded this course – until, as they told Reprieve, “concerns about risk and value for money” led them to cancel it.[16] This assistance raises serious concerns that CSSF-funded training is being given to Ethiopian security forces and used to commit serious rights abuses – rendering the UK Government potentially complicit in their wrongdoing.
  9. The Ethiopian Government’s receipt of CSSF funding was only revealed in response to a Freedom of Information request by Reprieve, and still no other information is available elsewhere. In light of the role of this funding in training abusive security forces in Ethiopia and elsewhere, –the lack of detail on how the UK Government ensures that the funding is compliant with fundamental human rights remains a serious concern.

MORE THAN TWO THIRD OF CSSF SPENDING IS STILL UNACCOUNTED FOR

  1. Despite serious concerns that the money may be funding human rights abuses, the vast majority of CSSF spending remains undocumented and secret. Reprieve has tallied the figures for all funding released publicly in July 2017 as country programme expenditure, and we found that this amounts to around £316 million – well short of the £1.1 billion total. In fact, this leaves almost £800 million unaccounted for, which is nearly three quarters of the entire fund.
  2. In fact, as the JCNSS found, much of the remainder is used to fund “other conflict-related activity”,[17] without specifying exactly how this allocation would be made or how recipients would be vetted. This appears to amount to a category of secret spending towards programmes which may well have serious human rights implications.
  3. Reprieve recognises that details of some programmes may need to remain secret where to publish them would seriously threaten national security. But as the JCNSS said, “[w]e agree with the human rights group Reprieve” that a blanket policy to leave secret vast swathes of CSSF funding cannot be right.[18]
  4. A minority of this spending may include between £300-390 million of CSSF funds earmarked for UN peacekeeping programmes.[19] This is only a fraction of the expenditure of which is covered by public documents detailing CSSF-funded peacekeeping operations.[20] As the inquiry found, “[a]bout half of the total” CSSF budget is available for discretionary programmes, and the rest is earmarked for peacekeeping and “other conflict-related activity” – without properly clarifying what this latter category entails.[21]
  5. Further, these figures suggest that almost half of the “discretionary” fund could itself be secret. Funding for discretionary projects amounts to around half of the entire CSSF and, as these figures show, only half of that is in the public domain. As these figures show, we do not know what is being funded, and what risks this funding may pose for human rights around the world.

INADEQUATE ASSESSMENT OF HUMAN RIGHTS RISKS

  1. UK Government assistance with foreign security forces raises serious concerns about compliance with its Overseas Security and Justice Assistance (OSJA) policy, and whether this policy is fit for purpose. This policy was introduced to prevent UK complicity in human rights abuses abroad following the Arab Spring, when it was revealed that British forces trained foreign security bodies, including Colonel Gaddafi's secret police.
  2. Since its introduction, Parliament has criticised the lack of transparency surrounding the policy. In a 2016 report, the Home Affairs Committee found that a Minister’s refusal to disclose even basic information about UK police assistance projects overseas was “totally unacceptable” and questioned “whether the OSJA guidance is fit for purpose”.[22]
  3. The OSJA policy only provides protection for human rights if it is applied correctly. Without any transparency or oversight, monitoring the OSJA policy is impossible. It is now clearer than ever that the UK needs a transparent, robust risk assessment process which is consistently applied across all government agencies when providing assistance to regimes with questionable human rights policies.
  4. Unfortunately, it remains wholly unclear how the OSJA Policy is applied, and whether this is done so properly, safely, or even at all. The Government refuses to publish anything of its OSJA assessments, leaving the public in the dark as to whether CSSF spending is being properly monitored. In fact, the Government admitted in 2014 that different departments and agencies are only partially or poorly applying the OSJA policy[23], and accepted in 2017 that “[d]epartments apply their own systems of scrutiny” when reviewing their CSSF spending.[24]
  5. As they stated in evidence before the International Development Committee’s Sub-Committee, ICAI criticised the Government for its failure to demonstrate that it even conducts these assessment:

“We have not seen evidence that the UK Government consistently and sufficiently thoroughly conduct human rights risk assessments…We have gone quite out of our way, almost to an embarrassing extent, to try to make sure that this is actually because the evidence does not exist, because the two alternatives are that the evidence exists but we do not get it, or the evidence exists but they cannot find it…We did not find it to a satisfactory extent.”[25]

  1. As ICAI later found in its recent report, the CSSF’s human rights risk assessments are “inconsistent” and programme monitoring “often weak” – with an “absence of results monitoring”[26]. As a result, it said that “we do not know if CSSF programming is causing harm.”[27] This is the despite the real risk, as ICAI found, that working with security forces accused of human rights violations “risks legitimising them and their actions, or even becoming complicit in violations”.[28]
  2. ICAI reviewed a sample of OSJA assessments for CSSF programmes, and found serious problems:

“Several OSJAs were produced after programming had commenced and some OSJAs were incomplete or of low quality (typically with a stronger analysis of the UK’s reputational risks than of the risk of CSSF support aggravating human rights violations) or had not been conducted at all. The human rights assessments within our sample always gave the green light for the proposed activity, without requiring any design modifications. This may be the consequence of a small sample but it raises a concern as to whether these assessments are an effective control mechanism.”[29]

  1. As the BBC, Guardian, and Daily Mail further reported, the lack of accountability and risk assessments raise serious concerns that the CSSF may be “doing harm”.[30]
  2. There remains a serious lack clarity and consistency as to whose responsibility it is to ensure that these assessments are properly carried out for all CSSF funding. The Government still refuses to release OSJA assessments – leaving it unclear as to whether human rights assessments might be flawed or inaccurate, or were even conducted at all.
  3. The Government should ensure that these programmes are doing what they promise, are providing value for money, and that lessons are learned when mistakes are made. The JCNSS was told by Government that officials monitored CSSF programmes and generated written reviews after implementation.[31] But only a small portion of these reviews has been released, and even then only in summary form, with only a fifth of the over £1 billion fund covered by the published reviews.
  4. However, ICAI recently found that, despite JCNSS calling for such documentation to be made available, it is inadequate and in fact may not exist. As ICAI stated, “we found that evidence required to verify the portfolio’s value for money does not exist”, with an “absence of results monitoring”.[32] As they concluded, “The lack of meaningful results data means that neither the CSSF nor external reviewers such as ourselves can ascertain whether CSSF investments are effective and achieving good value for money.”[33]
  5. Further, over-classification may be hampering the Fund from learning from its mistakes. As ICAI has stated, “sensitivity and confidentiality are used as arguments for the decision not to share information and not to invite outsiders into learning events”, with evidence suggesting that “this justification is over-used” and that “the lack of transparency inhibits learning”.[34]
  6. Even the available reviews – with more controversial programmes likely still unpublished – show the urgent need for greater accountability. The recently published reviews, for example, appear to provide no information on the human rights risks these programmes might have posed, what was done about them, and whether the risks were properly mitigated or avoided.
  7. In one review, for example, a programme run by the Ministry of Defence to train the Nigerian armed forces is rated as “High risk”, but despite the widespread reports of human rights abuses committed by the Nigerian military[35] the document provides no detail on how the risks of such cooperation were mitigated, if they were.[36]
  8. Despite these concerns, programmes such as this are ones for which there are published reviews, with evaluation of the vast majority of the money spent still undisclosed. This leaves the impact, effectiveness, and safety of £1 billion of taxpayer funds worryingly unclear, and raises the question of whether programmes that have resulted in serious rights violations are being ignored and not learnt from.

IS THE AID BUDGET FUNDING SECRET POLICE?

  1. Another serious concern is that CSSF spending is blurring important boundaries between development aid and security and justice assistance. 47% of CSSF spending in 2016 to 2017 was classified as Overseas Development Assistance (ODA),[37] despite the existence of clear guidelines on just what can be classified as ODA and what cannot, set by the Organisation for Economic Cooperation and Development (OECD). With so much of the CSSF budget secret, it remains unclear just which CSSF projects are being classed as aid.
  2. As the Government’s Annual Report on the CSSF admits, this means CSSF funding counts towards the Government’s UN commitment to spend 0.7 of Gross National Income each year on development aid, despite the fact that much of it used to train or assist foreign security forces.[38] As the National Security Committee found, CSSF spending also helps it meet its NATO commitment of spending 2% of Gross Domestic Product on defence, a concerning example of double-counting which risks blurring the goals of each area of spending.[39]
  3. Others have raised concerns about the CSSF’s blurring of important boundaries in aid spending. In its recent report, ICAI identified cases in which ODA money had been spent on projects of potentially dubious aid value, chiefly to gain access to figures in the governments of the region:

“We were concerned to find cases where the CSSF had embarked on ODA projects that had limited prospects of success, because they believed the investment would provide the UK with diplomatic access to key actors in government. While diplomatic and development goals can converge, a grey area emerges when the stated objective of an ODA-funded project is actually serving an unstated diplomatic objective, over which there is limited reporting and accountability.”[40]

 

  1. Since we know little as to the majority of CSSF spending, it is not clear whether it meets the OECD guidelines on aid. In view of the kinds of security programmes for which CSSF funding is typically used, there are serious concerns that money which should be spent on development aid is being used to finance security cooperation.
  2. In fact, the Government has indicated in its ODA strategy that it intends to alter the definition of ODA so as to fold in as much CSSF spending as it can, stating, “The Government will continue to work closely with other countries to modernise the definition of ODA at the OECD.”[41] It further made this aim clear in the 2017 Conservative Party Manifesto, pledging to change the rules to “better reflect the breadth of our assistance around the world.”[42]
  3. Since it began seeking to class military assistance as aid, the Government has successfully lobbied the OECD to widen the definition to include military training and counter-terror cooperation where the purpose can be said to be “developmental”.[43]
  4. If the Government wishes to widen the definition of ODA to include such activity, it should do so publicly and open the issue up to real public debate. Without much-needed transparency, the public do know how their money is being spent – and whether taxpayers’ contributions to development aid are actually funding secret police.

CRITICISM FROM INDEPENDENT REVIEWERS REMAINS UNHEEDED

  1. In January 2017, the JCNSS voiced severe criticisms over the way the fund is run.[44] The Committee had serious concerns as to the lack of public information about the fund, calling the CSSF “opaque” and urging the Government to make it “more transparent”.
  2. It also found that the CSSF “lacks political leadership and accountability” without an individual responsible Minister, leading to “the risk that nobody takes responsibility”, despite the significant risks to human rights. It also worried that the fund remains both operated and reviewed by the same body, the National Security Council (NSC), with the result that “the NSC is in effect marking its own homework in relation to the CSSF.”[45]
  3. Most worryingly, whilst the Government claims that the Committee is meant to oversee the CSSF, it failed to provide it with the evidence it needed to conduct any oversight at all, as the Committee protested.[46] As a result, it concluded that “the jury is out” on whether it is working properly, or whether it is simply a “slush fund”.[47]
  4. The Government has still to properly implement the Committee’s recommendations. Whilst it has released an Annual Report, along with some details of CSSF country programmes, these disclosures have largely restated information the Government had already provided to the Committee in 2016. Further, as Reprieve has found, the published details of country programmes leave hundreds of millions of pounds of CSSF spending unaccounted-for, raising further questions about the fund’s transparency, accountability, and risks to human rights.
  5. Since the JCNSS published its report, ICAI published its review that underscored the Committee’s findings and raised concerns of its own. In addition to the criticisms identified above, ICAI found several examples of ineffective or counterproductive expenditure with little transparency or accountability.
  6. ICAI has serious concerns with the Fund’s value for money and impact, finding that “[r]esults management practices are inadequate, given the scale of the funding”, with “little reliable data on whether projects are achieving their intended results or delivering value for money.”[48] It found that the approach taken by programmes it studied “contradicts the available evidence on what works” and identified “many instances of poor design and delivery”.[49]
  7. In reviewing available documentation, ICAI found an “absence of results monitoring”, and revealed that “evidence required to verify the portfolio’s value for money does not exist.”[50] As ICAI concluded, “The lack of meaningful results data means that neither the CSSF nor external reviewers such as ourselves can ascertain whether CSSF investments are effective and achieving good value for money.”[51]
  8. The Government has yet to respond to ICAI’s criticisms and recommendations.

UNANSWERED QUESTIONS

 

  1. Despite recent attempts by Government to respond to criticisms made by Parliament, it has done little to allay concerns. Serious questions remain:

 

 

RECOMMENDATIONS

 

  1. The CSSF risks leaving the UK complicit in human rights abuses overseas. Reprieve has documented several cases of Government complicity in abuses by foreign security forces in countries known to receive significant sums in CSSF funding. Despite this, the Government has yet to provide sufficient detail on the CSSF to allow independent review, and to demonstrate that the spending is transparent, accountable, and safe.
  2. The public still knows too little and the risks remain too great for the Government not to act now. Reprieve makes the following recommendations:

 

REFERENCES


[1] The sums available have increased over time, starting in 2015 at £1.03 billion, then rising to £1.16 billion in 2017. It is planned to rise to a total of £1.32 billion by 2019. For 2015, see Written Statement: Conflict Stability and Security Fund Settlement, Financial Year 2015-16, 12 March 2015, available here: http://www.parliament.uk/business/publications/written-questions-answers-statements/written-statement/Commons/2015-03-12/HCWS392/. For 2017, see Written Statement: Conflict, Stability and Security Fund 2016 to 2017 and settlement for 2017 to 2018, 19 July 2017, available here: https://www.gov.uk/government/speeches/conflict-stability-and-security-fund-2016-to-2017-and-settlement-for-2017-to-2018-written-ministerial-statement. For projected 2019 expenditure, see Written Statement: Conflict Stability and Security Fund 2015/16 and settlement for 2016 /17, 21 July 2016, available here: https://www.parliament.uk/business/publications/written-questions-answers-statements/written-statement/Commons/2016-07-21/HCWS123/

[2] Independent Commission for Aid Impact, ‘The Conflict, Stability and Security Fund's aid spending A performance review’, March 2018, available at: https://icai.independent.gov.uk/wp-content/uploads/The-CSSFs-aid-spending-ICAI-review.pdf, pp. 23 and 36.

[3] There are 52 documents relating to country programmes on the CSSF website: see ‘Conflict, Stability and Security Fund: programme summaries’, 19 July 2017, available here: https://www.gov.uk/government/collections/conflict-stability-and-security-fund-programme-summaries. Of these, approximately 36 involve the training of or collaboration with foreign security, police, or other forces, or otherwise have significant human rights implications.

[4] Joint Committee on the National Security Strategy, ‘Conflict, Stability and Security Fund’, Second Report of Session 2016–17, 30 January 2017, available at: https://publications.parliament.uk/pa/jt201617/jtselect/jtnatsec/208/208.pdf, p. 10.

[5] JCNSS report, January 2017, p. 21.

[6] See JCNSS Written Evidence submitted by the Bahrain Institute for Rights and Democracy, 2016, available here: http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/national-security-strategy-committee/conflict-stability-and-security-fund/written/38255.pdf.

[7] Reprieve, ‘UK trained hundreds of guards at Bahrain’s death row prison, new report finds’, 29 September 2016, available here: https://www.reprieve.org.uk/press/uk-trained-hundreds-of-guards-at-bahrains-death-row-prison-new-report-finds/.

[8] The National, ‘Bahrain amends law to ban Manama protests’, 8 August 2013, available here: https://www.thenational.ae/world/mena/bahrain-amends-law-to-ban-manama-protests-1.472136. See also Bahrain Institute for Rights and Democracy, ‘18-year-old Mustafa Hamdan dies after security forces shooting’, 24 March 2017, available here: http://birdbh.org/2017/03/18-year-old-mustafa-hamdan-dies-after-security-forces-shooting/, and ‘Bahrain Police Raid Duraz Sit-in, Killing 5 and Injuring Dozens’, 24 May 2017, available here: http://birdbh.org/2017/05/bahrain-police-raid-duraz-sit-in-killing-5-and-injuring-dozens/.

[9] NI-CO Response to Freedom of Information Act 2000 Request dated 7 September 2016, (28 October 2016).

[10] NI-CO Response to Freedom of Information Act 2000 Request dated 7 September 2016, (28 October 2016.

[11] Reprieve, ‘Evidence submission by Reprieve’, 2017, available here: http://data.parliament.uk/WrittenEvidence/CommitteeEvidence.svc/EvidenceDocument/Joint%20Committee%20on%20the%20National%20Security%20Strategy/Conflict,%20Stability%20and%20Security%20Fund/written/38225.html.

[12] Human Rights Watch, ‘Addressing the Pervasive Human Rights Crisis in Ethiopia: Letter to the UN Human Rights Council’, 25 May 2017, available here: https://www.hrw.org/news/2017/06/02/addressing-pervasive-human-rights-crisis-ethiopia.

[13] United Nations Human Rights Council Office of the High Commissioner, ‘UN experts urge Ethiopia to halt violent crackdown on Oromia protesters, ensure accountability for abuses’, 21 January 2016, available here: http://www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=16977&.

[14] See Ethiopian Reporter, ‘David Cameron’s Visit to Ethiopia will Focus on Security Issues, 2 March 2016. Translation on file with Reprieve.

[15] See Reprieve, 2017.

[16] Reprieve, ‘UK ‘training Ethiopian forces’ linked to Brit’s kidnap’, 21 March 2016, available here: https://www.reprieve.org.uk/press/uk-training-ethiopian-forces-linked-to-brits-kidnap/.

[17] JCNSS report, January 2017, pp. 26-7.

[18] JCNSS report, January 2017, p. 31.

[19] The amount is approximate, since Government sources state the figure as either £300 million, £350 million, or £385.7 million: for each, respectively, see Written Statement, 19 July 2017; ‘Annual Report’, 19 July 2017, p. 16; and ‘Written evidence submitted by HM Government (CSS0019)’, to JCNSS inquiry, 14 September 2016, available here: http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/national-security-strategy-committee/conflict-stability-and-security-fund/written/40690.pdf, pp. 1-2.

[20] Very few of the publicly available county programme notes cover UN peacekeeping expenditure.

[21] JCNSS report, January 2017, pp. 26-7.

[22] College of Policing: three years on, Fourth Report of Session 2016–17, House of Commons Home Affairs Committee, https://publications.parliament.uk/pa/cm201617/cmselect/cmhaff/23/23.pdf.

[23] Foreign and Commonwealth Office Business Plan, July 2015: http://webarchive.nationalarchives.gov.uk/20150703105958/http:/transparency.number10.gov.uk/business-plan-pdf/9

[24] ‘Written evidence submitted by HM Government (CSS0019)’, to JCNSS inquiry, 2016, p. 8.

[25] International Development SubCommittee on the Work of the Independent Commission for Aid

Impact, “Oral evidence: ICAI’s reviews on (1) the UK’s aid response to irregular migration in the Central

Mediterranean; (2) reducing conflict and fragility in Somalia, HC 443”, 18 October 2017, available here: http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/international-development-subcommittee-on-the-work-of-the-independent-commission-for-aid-impact/icais-reviews-on-1-uk-response-to-migration-in-the-central-mediterranean-2-uk-aid-in-somalia/oral/71758.pdf, pp. 2-3, evidence of Willem van Eekelen, Team Leader, ICAI.

[26] ICAI, March 2018, pp. 23 and 37.

[27] ICAI, March 2018, p. 37.

[28] ICAI, March 2018, p. 29.

[29] ICAI, March 2018, p. 29.

[30] BBC News, ‘International aid: Government fund 'could be causing harm'’, 29 March 2018, available at: http://www.bbc.co.uk/news/uk-43572783, Guardian, ‘Watchdog warns £1.2bn aid fund leaves UK at risk over human rights abuses’, 29 March 2018, available at: https://www.theguardian.com/global-development/2018/mar/29/watchdog-warns-1bn-aid-conflict-fund-leaves-uk-at-risk-of-liaising-human-rights-abusers-icai, Daily Mail, ‘£1billion-a-year fund to spread peace to war-torn countries using overseas aid cash ‘may be causing harm’, 29 March 2018, available at: http://www.dailymail.co.uk/news/article-5556475/1billion-year-fund-spread-peace-war-torn-countries-using-aid-cash-causing-harm.html.

[31] JCNSS report, January 2017, pp. 38-9.

[32] ICAI, March 2018, p. 23.

[33] ICAI, March 2018, p. ii.

[34] ICAI, March 2018, pp. 34 and iv.

[35] For example, New York Times, ‘Abuses by Nigeria’s Military Found to Be Rampant in War Against Boko Haram’, 3 June 2015, available at: https://www.nytimes.com/2015/06/04/world/africa/abuses-nigeria-military-boko-haram-war-report.html.

[36] Annual Review – Summary Sheet, ‘North East Nigeria Security and Conflict & Stabilisation’, available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/668316/Northeast_Nigeria_Security_and_Conflict_Stabilisation_Annual_Review.pdf.

[37] HM Government, ‘Conflict, Stability and Security Fund: Annual Report 2016/17: A Cross-Government approach to tackling insecurity and instability’, July 2017, available here:  https://publications.parliament.uk/pa/jt201617/jtselect/jtnatsec/1134/1134.pdf, p. 10.

[38] HM Government, ‘Annual Report 2016/17’, July 2017, p. 10.

[39] JCNSS report, 2016, p. 8.

[40] ICAI, March 2018, p. 26.

[41] HM Treasury and Department for International Development, ‘UK Aid: Tackling Global Challenges in the National Interest’, November 2015, p. 10, paragraph 2.15, available here:  https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/478834/ODA_strategy_final_web_0905.pdf. Emphasis added.

[42] Conservative and Unionist Party, ‘Forward, Together: Our Plan for a Stronger Britain and a Prosperous Future’, 2017, available here: https://s3.eu-west-2.amazonaws.com/manifesto2017/Manifesto2017.pdf.

[43] OECD, Development Assistance Committee (DAC) Communiqué, 19 February 2016, available here: https://www.oecd.org/dac/DAC-HLM-Communique-2016.pdf. See also The Guardian, ‘Concerns raised over government attempts to redefine overseas aid’, 25 January 2016, available here: https://www.theguardian.com/global-development/2016/jan/25/uk-government-lobbying-changes-overseas-aid-definition-international-development-budget.

[44] JCNSS, January 2017.

[45] JCNSS report, January 2017, p. 13.

[46] HM Government, ‘Annual Report 2016/17’, July 2017, p. 8.

[47] JCNSS report, January 2017, pp. 3-4, 13, 29, and 31.

[48] ICAI, March 2018, p. 40.

[49] ICAI, March 2018, p. ii.

[50] ICAI, March 2018, p. 23.

[51] ICAI, March 2018, p. ii.