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									Programme Management Guidelines



               Part 1



Programme Implementation Manual (PIM)




               CFCU-2009
                                                Programme Implementation Manual (PIM)


                                                           Table of Contents
     LIST OF ABBREVIATIONS ..................................................................................................................................... 5
FOREWORD.............................................................................................................................................. 6
1.      GENERAL ISSUES ........................................................................................................................... 7
     1.1      OPERATIONAL AGREEMENT ...................................................................................................................... 7
     1.2      PROGRAMME MANAGEMENT GUIDELINES................................................................................................. 7
     1.3      THE PIM, POG AND PTR .......................................................................................................................... 8
     1.4      LEGISLATIVE UNDERPINNINGS .................................................................................................................. 9
     1.5      SELF ASSESSMENT OF SPO OFFICES & PROJECT TEAM CONTACTS BY PROJECT OR MINISTRY / AGENCY 9
2.      EU PRE-ACCESSION ASSISTANCE ........................................................................................... 11
     2.1 INSTRUMENT FOR PRE-ACCESSION ASSISTANCE ..................................................................................... 11
     2.2 INSTITUTIONAL ARRANGEMENTS FOR IPA .............................................................................................. 12
        2.2.1. European Commission Delegation (ECD) .................................................................................... 12
     2.3 THE PHASES OF PROJECT PREPARATION AND IMPLEMENTATION ............................................................. 12
        2.3.1. Programming ................................................................................................................................ 13
        2.3.2. Implementation .............................................................................................................................. 14
     2.4 PROGRAMME CYCLE ............................................................................................................................... 14
     2.5 MORE ON THE PROJECT CYCLE ............................................................................................................... 16
        2.5.1. Programming ................................................................................................................................ 17
        2.5.2. Identification ................................................................................................................................. 17
        2.5.3. Formulation................................................................................................................................... 17
        2.5.4. Financing ...................................................................................................................................... 17
        2.5.5. Implementation .............................................................................................................................. 17
        2.5.6. Evaluation ..................................................................................................................................... 18
3.      DECENTRALISED IMPLEMENTATION SYSTEM ................................................................. 19
     3.1 OVERVIEW............................................................................................................................................... 19
     3.2 DIS INSTITUTIONS ................................................................................................................................... 20
        3.2.1. National IPA Coordinator (NIPAC) .............................................................................................. 20
        3.2.2. Financial Co-operation Committee (FCC) ................................................................................... 20
        3.2.3. National Fund (NF) ....................................................................................................................... 20
        3.2.4. National Authorising Officer (NAO) ............................................................................................. 20
        3.2.5. Central Finance and Contracts Unit (CFCU) .............................................................................. 20
        3.2.6. Programme Authorising Officer (PAO) ........................................................................................ 21
        3.2.7. Senior Programme Officer (SPO) ................................................................................................. 21
        3.2.8. Transition Assistance and Institution Building Committee (TAIB Committee) ............................. 22
4.      ROLE OF THE SPO AND THE PROJECT TEAM .................................................................... 24
     4.1 MISSION .................................................................................................................................................. 24
     4.2 SCOPE OF WORK ...................................................................................................................................... 24
        4.2.1. Implementing Agreements – Operational Agreement ................................................................... 24
     4.3 PROJECT DEVELOPMENT ......................................................................................................................... 26
        4.3.1. Financing Procedures ................................................................................................................... 27
        4.3.2. Line Ministry or Agency Tasks and Responsibilities ..................................................................... 27
        4.3.3. Financing Agreement (FA) ............................................................................................................ 27
        4.3.4. Implementation Documents ........................................................................................................... 27
     4.4 PROJECT IDENTIFICATION ........................................................................................................................ 28
        4.4.1. Identification Procedures .............................................................................................................. 28
        4.4.2. Line Ministry or Agency Tasks and Responsibilities ..................................................................... 28
        4.4.3. Co-financing.................................................................................................................................. 29
     4.5 PROJECT FORMULATION .......................................................................................................................... 30
        4.5.1. Formulation Procedures ............................................................................................................... 30
        4.5.2. Line Ministry or Agency Tasks and Responsibilities ..................................................................... 30
        4.5.3. The Project Fiche (PF) ................................................................................................................. 31
     4.6 TYPES OF INSTITUTION BUILDING PROJECTS ........................................................................................... 32
        4.6.1. Technical Assistance (TA) ............................................................................................................. 32
        4.6.2. Standard Twinning ........................................................................................................................ 33


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        4.6.3.         Twinning Contract ........................................................................................................................ 34
        4.6.4.         Standard Twinning Preparation Procedures ................................................................................ 34
        4.6.5.         Twinning Light .............................................................................................................................. 35
5.      IMPORTANCE OF STARTING IMPLEMENTATION ACTIONS EARLY ........................... 37
     5.1 LAST MINUTE CONTRACTING .................................................................................................................. 37
        5.1.1. Time Scheduling Diagram for a Service Contract >€200,000. ..................................................... 37
        5.1.2. Time Schedule and FA Time Limits ............................................................................................... 37
     5.2 ASSESSING THE QUALITY OF A PROJECT PROPOSAL ................................................................................ 38
        5.2.1. Relevancy ...................................................................................................................................... 38
        5.2.2. Feasibility...................................................................................................................................... 39
        5.2.3. Sustainability ................................................................................................................................. 39
     5.3 UNDERSTANDING THE LOGICAL FRAMEWORK ........................................................................................ 39
        5.3.1. The Logframe ................................................................................................................................ 39
        5.3.2. Intervention Logic ......................................................................................................................... 40
        5.3.3. Specifying Assumptions/ Risks....................................................................................................... 41
        5.3.4. Factors Ensuring Sustainability .................................................................................................... 41
        5.3.5. Analysis of Factors Affecting Sustainability.................................................................................. 41
        5.3.6. Objectively Verifiable Indicators .................................................................................................. 41
        5.3.7. Means of Verification .................................................................................................................... 41
        5.3.8. Means and Costs ........................................................................................................................... 41
     5.4 FRAMEWORK CONTRACTS ....................................................................................................................... 42
        5.4.1. FWC Service Mobilization ............................................................................................................ 42
        5.4.2. FWC ToR ....................................................................................................................................... 42
        5.4.3. Role of SPO ................................................................................................................................... 42
6. MANAGEMENT, MONITORING AND EVALUATION OF ASSISTANCE AND RECORD
KEEPING ................................................................................................................................................. 44
     6.1 THE PROJECT STEERING COMMITTEE ...................................................................................................... 44
     6.2 TAIB COMMITTEE MEETINGS .................................................................................................................. 45
     6.3 PROJECT EVALUATION ............................................................................................................................ 46
        6.3.1.     Evaluation Procedures .................................................................................................................. 46
        6.3.2.     SPO Role and Tasks ...................................................................................................................... 47
        6.3.3.     Evaluation Process and Methodology ........................................................................................... 47
     6.4 CHECKLIST OF ACTIVITIES REQUIRED FROM SPO ................................................................................... 49
        6.4.1.     Planning, Identification and Formulation ..................................................................................... 49
        6.4.2.     Implementation .............................................................................................................................. 50
        6.4.3.     Project Technical and Administrative Management ..................................................................... 50
     6.5 CHECKLIST FOR REGULAR MEETINGS ...................................................................................................... 52
        6.5.1.     Sectoral Monitoring Sub-committees Meeting .............................................................................. 52
        6.5.2.     Steering Committee Meeting ......................................................................................................... 53
        6.5.3.     TA Coordination Meeting.............................................................................................................. 53
     6.6 PUBLICITY AND VISIBILITY ..................................................................................................................... 54
        6.6.1.     Objective and EC Requirements.................................................................................................... 54
        6.6.2.     Tools .............................................................................................................................................. 55
        6.6.3.     Communication Plan ..................................................................................................................... 55
     6.7 RECORD KEEPING BY THE PROJECT TEAM ................................................................................................... 56
        6.7.1. Filing ................................................................................................................................................... 56
        6.7.2. Retention Policy .................................................................................................................................. 56
7.      RISK ANALYSIS ............................................................................................................................. 57
     7.1 SOURCES OF RISK .................................................................................................................................... 57
        7.1.1. External Risks................................................................................................................................ 57
        7.1.2. Process Risks ................................................................................................................................. 58
     7.2 DEVELOP A RISK MANAGEMENT POLICY ................................................................................................ 59
        7.2.1. Effectiveness Risks Management ................................................................................................... 59
        7.2.2. Efficiency Risks Management ........................................................................................................ 60
        7.2.3. Human Resources Risks Management .......................................................................................... 60
        7.2.4. Partner Satisfaction Risks Management ....................................................................................... 61
     7.3 RISK ASSESSMENT BY THE SPO .............................................................................................................. 61
     7.4 RISK MANAGEMENT PROCESS OF THE SPO ............................................................................................. 62


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     7.5      SENSITIVE POSTS ..................................................................................................................................... 63
8.      PREVENT, HANDLE AND REPORT IRREGULARITIES AND FRAUDS ............................ 65
     8.1 IRREGULARITY ........................................................................................................................................ 65
     8.2 FRAUD ..................................................................................................................................................... 65
     8.3 SOURCES OF IRREGULARITY .................................................................................................................... 65
        8.3.1. Irregularities that may Concern Line Ministry or Agency Staff .................................................... 65
        8.3.2. Irregularities that may Concern the Contractors .......................................................................... 66
        8.3.3. Irregularities that may Concern the Beneficiaries of GS .............................................................. 66
     8.4 DEVELOP IRREGULARITIES PREVENTION POLICY .................................................................................... 66
        8.4.1. Classification, Formalisation of Procedures and Information ...................................................... 66
        8.4.2. Preventive Actions – General Features ......................................................................................... 66
        8.4.3. Preventive Actions – Specific Features ......................................................................................... 67
     8.5 REACTION TO DETECTED IRREGULARITIES .............................................................................................. 68
     8.6 REPORTING IRREGULARITIES ................................................................................................................... 69
9.      HUMAN RESOURCES AND ETHICAL BEHAVIOUR ............................................................ 71
     9.1 HUMAN RESOURCES REQUIREMENTS ...................................................................................................... 71
        9.1.1. Skills Needed ................................................................................................................................. 71
        9.1.2. Grant Management Teams ............................................................................................................ 71
     9.2 CONDUCT TRAINING NEEDS ANALYSIS ................................................................................................... 72
     9.3 ETHICS POLICY ........................................................................................................................................ 72
        9.3.1. Principles of Ethical Conduct ....................................................................................................... 73
        9.3.2. Standards ...................................................................................................................................... 74
        9.3.3. Abuse of Official Capacity ............................................................................................................ 74
        9.3.4. Abuse of Official Information ........................................................................................................ 74
        9.3.5. Benefits, Gifts, Honoraria and Travels, Conference Attendance .................................................. 75




                                                                       Appendices

                   1. Operational Agreement CFCU/SPO<Ministry/Agency>
                   2. Memorandum of Understanding (MoU) on the Establishment of the CFCU
                   3. Framework Agreement
                   4. Self Assessment Sheet
                   5. Project Fiche (PF) Template
                   6. TS Guideline
                   7. Guide to FWC
                   8. Publicity and Visibility
                   9. Sensitive Post Policy Paper




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                                     List of Abbreviations
AA         Audit Authority
AP         Accession Partnership
APD        Annual Planning Document
BC         Beneficiary Country
CAO        Competent Accrediting Officer
CARDS      Community Assistance for Reconstruction, Development and Stabilisation
CBC        Cross Border Cooperation
CFCU       Central Finance and Contracts Unit
CV         Curriculum Vitae
DG ELARG   Directorate General for Enlargement
DG REGIO   Directorate General for Regional Policy
DIS        Decentralised Implementation System
DPT        State Planning Organization
EC         European Commission
ECD        European Commission Delegation to Turkey
EEA        European Economic Area
EDIS       Extended Decentralised Implementation System
ESC        Economic and Social Cohesion
EU         European Union
EUSG       Secretariat General for European Union Affairs
FA         Financing Agreement
FCC        Financial Cooperation Committee
FWA        Framework Agreement
FWC        Framework Contract
GS         Grant Scheme
HRD        Human Resource Development
IA         Implementing Agency
IET        Interim Evaluation Team
IPA        Instrument for Pre-Accession Assistance
IB         Institution Building
ISPA       Instrument for Structural Policies for Pre-Accession
MIPD       Multi-annual Indicative Planning Document
MoF        Ministry of Finance
MoU        Memorandum of Understanding
MR         Monitoring Report
MS         Member State
NAO        National Authorising Officer
NCP        National Contact Point
NF         National Fund
NIPAC      National IPA Coordinator (former NAC)
NPAA       National Programme for the Adoption of the Acquis
OP         Operational Programme
OS         Operating Structure
PAO        Programme Authorising Officer
PCM        Project Cycle Management
PF         Project Fiche
PHARE      Poland and Hungary Action for the Restructuring of the Economy
PIM        Programme Implementation Manual
PMG        Programme Management Guideline
POG        Project Operational Guide
PRAG       Practical Guide to EC External Aid Contract Procedures
RTA        Resident Twining Advisor
SAPARD     Special Pre-Accession Programme for Agriculture and Rural Development
SPO        Senior Programme Officer
SF         Structural Funds
SMSC       Sectoral Monitoring Sub Committee
SWOT       Strengths, Weaknesses, Opportunities and Threat Analysis
TA         Technical Assistance
TAIB       Transition Assistance and Institution Building
TNA        Training Needs Assessment
ToR        Terms of Reference
TS         Technical Specifications




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                           Programme Implementation Manual (PIM)



Foreword

At the moment we find all the essential components of a well operating DIS system are
present in Turkey. In so far as the capacity of SPOs is concerned we see also a DIS system
that is growing well. Of course it is not the finished product yet but that is to be expected;
these systems need time to take root fully in Accession countries and it takes time to provide
sufficient resources to the system in total so some delays are inevitable.
Programme Management Guidelines (PMG) should also be considered in this respect. The
purpose of this PMG is to support the SPOs in carrying out their responsibilities relating to
the operations under the IPA/DIS. Specifically, it covers,
       - the roles and responsibilities of the SPOs with a focus to the relations with the
       PAO/CFCU
       - information on the IPA/DIS structures within the context of the operations of the
       SPOs
We hope that SPO teams involved in the management of operations will find the contents
helpful. It is envisaged that the experience developed by the SPOs and their teams in using
this Guideline will be used in the preparation of future versions.


Muhsin Altun
PAO-CFCU Director




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                                    Programme Implementation Manual (PIM)




1. General Issues

If Turkey is to absorb European Union (EU) funds effectively then it must
       Spend the funds available (implement projects and present invoices)
       Choose the best spending options (programme effectively)
The aim of the Programme Management Guidelines (PMGs) is to ensure that the aims set out
for the Line Ministries and Agencies are being realised to ensure qualitative and effective
management of the Pre-accession Aid provided by the EU.


1.1 Operational Agreement

These PMGs are an aid for the Senior Programme Officers (SPOs) and their project teams for
the implementation of the Operational Agreement (Appendix 1) between Central Finance and
Contracts Unit (CFCU) and line ministries. The Parties to this Agreement have a common
responsibility in the implementation of the IPA Component-I Programmes for Turkey as
indicated in the Financing Agreement (FA), signed between the European Commission (EC)
and the Government of Turkey on an annual basis.
The division of the specific responsibilities of each party have been clearly defined in the
Memorandum of Understanding (MoU)1 on the establishment of the CFCU (Appendix 2),
signed between the EC and the Government of Turkey on 14 February 2002 and ratified by
the Grand National Assembly of Turkey on 29 January 2003, whereby

                the SPOs, under the overall responsibility of the PAO, is responsible for the
                    technical implementation of the EU-funded projects, while

                the CFCU, under the responsibility of the PAO, is responsible for the tendering,
                    contracting and payments relating to those projects,


1.2 Programme Management Guidelines

These PMGs have been developed with a twofold objective:

                Rationalise and systematise management and organisational structures and
                    procedures of the Project Teams, to be set up in each Line Ministry or Agency

1   As amended by Addendum No. 1 of 10 May 2006

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                           Programme Implementation Manual (PIM)


             under the responsibility of the SPO, to ensure an efficient and effective
             implementation of the EU funded projects

           Provide easy and friendly guidelines to accompany the SPO and his/her team
             along all phases of the project cycle technical and administrative management
The PMGs are based on the EC project technical management procedures (PCM Manual) and
project administration procedures (PRAG).
The PMGs will be reviewed and updated every six months by a working group composed of
at least five SPOs (or their delegates) and leaded by the Quality Assurance and Control
Department of the CFCU. The PAO shall take the initiative in convening the Working Group.
Should any discrepancy with the EC regulation occur the latter prevails over the PMGs.


1.3 The PIM, POG and PTR

The PMGs are in three parts:
A Programme Implementation Manual (PIM) provides an overview of actors and their
responsibilities, and the legal framework within which they work. It describes the different
activities to be undertaken under the SPO, (WHAT is to be done) and WHO is responsible for
undertaking those activities, in the framework of the programme. The PIM also describes the
overall management and control system from Steering Committee to Sectoral Monitoring
Committees (SMCs) to evaluation processes.
A Programme Operational Guide (POG) supports the PIM. It is comprised of a detailed set
of guidelines on HOW to carry out all of the activities; including instructions, checklists,
standard formats, etc.
Programme Training Resources (PTR) support the PIM and POG. These are training
programmes dealing with the core theoretical background of key activities relevant to the PIM
and POG. This extra section elaborates the theoretical underpinnings of selected areas and is
intended also as a resource for induction training for new recruits to the line ministry/agency.
It may serve also as a source of renewal training for longer serving officers.
PTR should be taken into consideration as together with the “DIS Training Policy” developed
by the NIPAC services.




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                          Programme Implementation Manual (PIM)



1.4 Legislative Underpinnings

Where Projects by the European Community in the course of co-operation with Republic of
Turkey are awarded by the Contracting Authority (CFCU), award procedures are governed by
following legal framework:

          the Financial Regulation No. 1605/2002 of 25 June 2002 (General budget of
             European Communities )

          Council Regulation (EC) No. 1085/2006 of 17 July 2006 – establishing the
             Instrument for Pre-Accession Assistance (IPA)

          Commission Regulation (EC) No.718/2007 of 12 June 2007 laying down the
             implementing rules governing the provision by the Community of the pre-
             accession assistance established by Council Regulation (EC) No. 1085/2006
             (IPA IR)

          Framework Agreement (FWA) signed by the EC and the Republic of Turkey
             ratified by the Grand National Assembly on 3 December 2008, which has been
             put into force by the Government Decree No. 2008/14450 that was published in
             the Official Gazette No. 27090 (Complementary Issue), dated 24 December
             2008.

          FA for each year of programming

          Practical Guide to EC External Aid Contract Procedures (PRAG), where are all
             procedures established by EC in the context of external actions are consolidated
The full EU and Turkish regulatory framework is at Appendix 3.

1.5 Self Assessment of SPO Offices & Project Team Contacts by
   Project or Ministry / Agency
All SPOs must assess themselves in a frank and open manner through Self-assessment in
Appendix 4 by providing supporting documents and submit to the CFCU together with the
information required in Table-1 at the tendering and contracting stage for supervision of the
PAO.




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                  Programme Implementation Manual (PIM)


                            Table 1 – SPO and Project Team
                                        Phone:
Senior Programme Officer:               Fax:
                                        e-mail:
                                        Phone:
Project Leader                          Fax:
                                        e-mail:
                                        Phone:
Project Coordinator                     Fax:
                                        e-mail:
                                        Phone:
Team Member(s)                          Fax:
                                        e-mail:




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                           Programme Implementation Manual (PIM)




2. EU Pre-accession Assistance

The EU Pre-accession Aid provides some very direct opportunities for accession countries to
learn and refine the approaches towards project selection under conditions of transparency
and objectivity. The experience of setting criteria for the IPA projects and the experience of
implementing the procurement and monitoring of those projects is generally invaluable
preparation for the accession countries.


2.1 Instrument for Pre-Accession Assistance

Instrument for Pre-accession Assistance (IPA) came into force on 1 January 2007, bringing all
pre-accession support into one single, focussed instrument.
The Council Regulation establishing IPA was adopted on 17 July 2006, replacing the 2000-06
pre-accession financial instruments PHARE, ISPA, SAPARD, the Turkish Pre-accession
Instrument, and the financial instrument for the Western Balkans, CARDS.
IPA covers the countries with candidate status (currently Croatia, the Former Yugoslav
Republic of Macedonia, and Turkey) and potential candidate status (Albania, Bosnia and
Herzegovina, Montenegro, Serbia and Kosovo).
IPA has five Components:
   I. Transition Assistance and Institution Building (TAIB) (which principally involves
       institution building (IB) measures with accompanying investment)
   II. Cross-Border Cooperation (CBC)
   III. Regional Development
   IV. Human Resources Development
   V. Rural Development
The latter three are for candidate countries and are designed to mirror structural funds (SF),
thus necessitating the relevant management structures to be in place. Potential candidates can
benefit from similar measures implemented through the component for TAIB.
IPA Component-I entails national and multi-beneficiary projects. It comes under the
responsibility of the Directorate-General for Enlargement (DG ELARG), which is also jointly
responsible for Component II - CBC with DG REGIO. DG ELARG is also responsible for the
overall co-ordination of pre-accession assistance.


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2.2 Institutional Arrangements for IPA

Under the IPA the following structures and authorities are planned:

           a National IPA Coordinator (NIPAC),

           a Strategic Coordinator (SC) for the Regional Development component and the
             Human Resources Development component,

           a Competent Accrediting Officer (CAO),

           a National Authorising Officer (NAO),

           a National Fund (NF),

           an Operating Structure (OS) by IPA component or programme ,

           an Audit Authority (AA).
In principle, for each IPA component or programme, an OS shall be established to deal with
the management and implementation of assistance under the IPA Regulation.
However, the OS(s) under the Component-I, in accordance with Article 75 of the IPA
Implementing Regulation, shall consist of one or more Implementing Agencies (IAs),
which is only the CFCU in Turkey. Furthermore, in a transition period, CFCU was
identified as a Contracting Authority responsible for all procedural aspects of the tendering
process, contracting matters and financial management including payment of project
activities to be carried out under the IPA components II, III and IV.
Component-V will have its own OS under EDIS, namely IPARD Agency under the Ministry
of Agriculture and Rural Affairs.

 2.2.1. European Commission Delegation (ECD)
The EC Delegation to Turkey is the representing body of the EC. One of the functions of the
ECD is the supervision of implementation of the IPA programmes including ex-ante approval
of certain documents.


2.3 The Phases of Project Preparation and Implementation

All EU spending must be in accordance with specific programming and implementation rules.
Programming is the process of deciding priorities; implementation is the process of absorbing
the allocated funds.




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                                      Programme Implementation Manual (PIM)


    2.3.1. Programming
The basic programming documents are the Accession Partnership (AP), the National
Programme for the Adoption of the Acquis (NPAA) and the Regular Country Reports.
These give rise to agreed priorities and then the next steps are followed:
       1. The Project Fiche (PF) is prepared and agreed between the involving institutions;
       2. The PF is submitted through the NIPAC to the EC. The EC prepares the Financing
            Proposal and submits it to the Management Committee for approval;
       3. The Management Committee2 approves the financial proposal with projects attached
            thereto. The FA is prepared by the EC.
       4. FA is signed by both EC and NIPAC and implementation starts.

Under the Decentralized Implementation System (DIS), the NAO also gives his explicit
written agreement to the PFs submitted by the NIPAC to the Commission. This agreement
shall be based on the assessment of the PAO.
Programming of EC financial assistance is the first phase in the project life cycle and is
coordinated by the Commission services with the active participation of the partner country.
The outcome of the programming process is the Financing Proposal drafted by the
Commission services. The Financing Proposal is the key programming document whilst the
programme is then implemented as set out in the PFs, which are the key implementation
documents.
The strategic priorities for programming will be established in the Multi-Annual Indicative
Planning Document (MIPD) which has a three year horizon and is subject to annual review.
The Programming for IPA Component-I is implemented through Annual Programmes,
following the priorities established in the MIPD while the other programmes are implemented
through multi-annual programmes.
Programming in the framework of IPA Component-II is likewise done annually, guided by
multi-annual Joint Programming Documents for the CBC Programmes.
The programming under IPA Components III-V, which prepares Turkey for future
participation in the SF, is guided by multi-annual Operational Programmes (OPs). For IPA
Components III and IV, the Turkish Government will establish a Strategic Coherence
Framework (SCF) for the entire IPA time period (2007-2013).
Under IPA Component-III (Regional Development), three OPs will be supported:
Environment, Transport, and Regional Competitiveness.
2   ex-Phare Committee now called IPA committee

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                           Programme Implementation Manual (PIM)


Under IPA Component-IV (Human Resource Development) and V (Rural Development), one
OP for each will be adopted.

 2.3.2. Implementation
Funds are FA specific and available for disbursement if held and within an n+3 disbursement
schedule from the signature of the underlying FA. Contracting must take place within 2 years
of the signature of the FA; disbursement within 3 years. These rules apply for all projects.


2.4 Programme Cycle

The process of preparing and implementing the FA, and the main actors are illustrated in the
diagram (Figure-1).
The main actors in the programming process are: -
Commission Services
National IPA Coordinator (NIPAC)
Line Ministries/Agencies (LM)
The main actors in the implementation process are: -
Commission Services
Central Finance and Contracts Unit (CFCU)
Line Ministries/Agencies (LM)

The key financial intermediary in the Beneficiary Country (BC) is the NF, which is entrusted
with receiving EU pre-accession funds transfers. All payments are based on the relevant
underlying FA.
There are several more second-level stakeholders involved either directly or in terms of
operational oversight within the visa system for any request for payments from the NAO. The
additional stakeholders involve the CFCU or other contracting bodies, the NIPAC and NAO
services and other Head of Operating Structures. Under the DIS, the ECD retains the
Commission‟s ex-ante control function and is also a key stakeholder.




                                             - 14 -
                                 Programme Implementation Manual (PIM)                                                 Figure 1
                                                                                                    IPA Programming and Project Implementation Cycle

       Programming Phase
                                                                                                   Implementation Phase
- Commission Services
                                                                                         - Commission Services
- NIPAC
                                                                                         - CFCU
- Line Ministries and Agencies
                                                                                         - Line Ministries and Agencies

                                                                                                            Working Document
                                                                                                         (Programme Document 1)
 Annual Enlargement Strategy                                                                                Quarter 4 in Year N-1
     Regular Report and
         Negotiations
                                                      Ex-post Evaluation of Financing                                                     Commission Decision
                                                                Agreement                                                                 Marking the budgetary
                                                              N+3 and beyond                                                                  commitment
   Accession Partnership (AP)                                                                                                              Quarter 3 in Year N


                                               Expiry and closing Audit of Financing
                                                            Agreement
                                                        After N+3 generally
      th
     9 Development Plan
                                                                                                                                          Financing Agreement
     Negotiation Framework                                                                                                              Country’s agreement with the
                                                                                                                                                Commission
                                               Monitoring and Assessment Reports                                                             Qr. 3-4 in Year N
                                               On clusters of Financing Agreement in
                                                        years N+2 and N+3




                                                                    Implementation – Tenders,                                          Financing Agreement
                                                                    Contracts and Management                                          National Fund delegation
                                                                  Derived directly from Project fiches                              agreement with Implementing
                                                                         Years N+1 and N+2                                                   Agency
                                                                                                                                      Quarter 1 in Year N+1




                                                 - 15 -
                           Programme Implementation Manual (PIM)



2.5 More on the Project Cycle

The project cycle represents the sequence of the different phases of the management of a
project, Figure 2:

             It starts with programming which means definition of objectives and priorities

           This lead to identification of project ideas which means actions aimed at
              achieving the set objectives and priorities

           Then it comes the formulation phase where the ideas are appraised and the most
              valuable are structured: resources needed, actions and expected results are
              identified

           Financial decisions are taken: Yes, the project will be funded

             Finally the project is implemented

           Last but not least, the project is evaluated to understand if it has achieved the set
              objective and if this was done within a reasonable period of time and with
              reasonable amount of resources
                                Figure 2: The Project Cycle

                                            Programming




    Evaluation                                                                    Identification




  Implementation                                                                   Formulation




                                              Financing




                                             - 16 -
                             Programme Implementation Manual (PIM)




 2.5.1. Programming
The purpose of the programming phase is to identify and agree the main objectives and
priorities for financial cooperation. Basic programming documents are the AP and NPAA
which set objectives and priority areas for the adoption of the Acquis Communautaire and the
Regular Reports which identifies the gaps in meeting the set objectives and priorities.

 2.5.2. Identification
In this phase, the line ministries and agencies are required to formulate project ideas through
Project Identification Sheets, in line with the set priorities and harmonization objectives.
Outcome of this phase is the identification of project proposals to be covered by the financial
cooperation.

 2.5.3. Formulation
In this phase, the line ministries and agencies are required to formulate PFs related to the
approved project proposals. Members of FCC may also take part to this phase in order to
ensure the consistency between programming and national budgetary requirements for co-
financing.

 2.5.4. Financing
This phase ends with the signature of the FA that includes PFs and related financial
envelopes, implementation monitoring and audit arrangements, anti-fraud measures.

 2.5.5. Implementation
This phase includes several steps:

              Preparation of project documents which describe define inputs and describe
                actions to be financed:
                                o ToR for technical assistance (TA)
                                o Technical Specification (TS) for supply of goods
                                o Guidelines for applicants for grant scheme (GS)
                                o Contracts for twinning programmes
                                o Detailed design for works

              Tendering and contracting to select the service provider applying open and fair
                competition methods



                                             - 17 -
                          Programme Implementation Manual (PIM)


           Project implementation and contract administration which is the phase where
             project activities are implemented and disbursements accordingly executed

           Monitoring to assess implementation performances and achievements in order to
             take corrective actions

 2.5.6. Evaluation
The aim of evaluation is to assess the impact of the project, if the objectives have been
achieved, and to learn lessons by identifying shortcomings and mistakes that occurred during
the implementation, in order to improve the execution of future projects.




                                            - 18 -
                            Programme Implementation Manual (PIM)



3. Decentralised Implementation System

The purpose of the DIS is to provide the appropriate legal and administrative framework for
the transfer of responsibilities for the implementation of the EU funded programmes from the
EC to the partner countries. Planning and programming systems remain the same, irrespective
of whether implementation is centralised or decentralised and the tendering and contracting
procedures are identical.


3.1 Overview

The EU Regulation aligns Turkey to the other member states (MSs) implying the adoption of
the DIS for the implementation of EU financial assistance.
Decentralisation involves the transfer of responsibility from the Commission to the recipient
country. The Contracting Authority as a national administration is responsible for the
tendering and contracting, as well as for the financial and administrative management of the
projects including payments.
Within the DIS-Turkey, the EC exercises systematic ex-ante controls; that is to say, the
decisions concerning the procurement and award of contracts are taken by the Contracting
Authority and referred for the prior approval of the ECD. In practice, the ex-ante control
decentralisation procedure carried out by the ECD involves four essential checks:

           Approving the content of the tender dossier and Procurement notice before the
             tender is launched,

           Approving the composition of the evaluation committee/shortlist panel (which is
             responsible for recommending a tenderer),

           Checking and approving the evaluation /shortlist report,

           The signature of the Head of the ECD on the contract itself, endorsement, not as
             a party to the contract but to confirm that the project is eligible to receive EU
             financing.
The very final objective of the decentralisation process is the establishment of an “Extended
Decentralised Implementation System – (EDIS)” (without „ex-ante‟ controls operated by the
EC) in Turkey.




                                            - 19 -
                          Programme Implementation Manual (PIM)



3.2 DIS Institutions

The main bodies established by Turkey for the management and implementation of DIS are as
follows:

 3.2.1. National IPA Coordinator (NIPAC)
Former NAC, General Secretary of the EU Affairs in charge of the programming within the
Republic of Turkey. The NIPAC also ensures a close link between the general accession
process and the use of EU financial assistance, and is responsible for the monitoring and
assessment of EU programmes. EUSG acts as secretariat of the NIPAC.

 3.2.2. Financial Co-operation Committee (FCC)
This body is not usual in the DIS but it has been introduced by the Turkish Government to
ensure proper coordination between the relevant ministries involved in EU financial co-
operation. It comprises the Ministry of Foreign Affairs, the Ministry of Finance (MoF), the
Undersecretariat of the State Planning Organization (DPT), the Undersecretariat of Treasury,
and the EUSG. The committee is chaired by the NIPAC.

 3.2.3. National Fund (NF)
This is the central treasury unit, within the Undersecretariat of Treasury, through which the
EU funds are channelled towards the recipient country.
The NF was established on the basis of the “MoU on the Establishment of the NF” , which
put in place a mechanism for the approval, use, monitoring and control of the EU funds. All
funds transferred from the Headquarters are sent directly to the NF, through the
Undersecretariat of Treasury, whose responsibility for financial accountability in accordance
with the FA rests with the NAO. In financial management of the EU funds, the NAO is the
main contact point between the Commission and Turkish Government. The NAO appoints the
PAO after the consultation with the NIPAC.

 3.2.4. National Authorising Officer (NAO)
Undersecretary of Treasury heads the NF. The NAO has the overall responsibility for the
financial management of EU funds in Turkey.

 3.2.5. Central Finance and Contracts Unit (CFCU)
The CFCU is an implementing body of the DIS within the national administration in charge
of projects financial, contractual and administrative management including tendering and



                                             - 20 -
                           Programme Implementation Manual (PIM)


payments. The SPO (see below) is responsible for the technical implementation of these
projects under the overall responsibility of the PAO.
The CFCU is the Contracting Authority responsible for the tendering, contracting,
administration, accounting, payments and financial reporting. The CFCU is headed by the
PAO.

 3.2.6. Programme Authorising Officer (PAO)
The PAO is an official of the national administration heading the CFCU or an IA. The PAO is
responsible for the operations of the CFCU/IA and for the sound financial management of the
projects to be implemented under the IPA Component-I in accordance with Article 28 of the
IPA IR.
To fulfil his responsibilities, the PAO shall supervise the technical implementation of the
SPOs.

 3.2.7. Senior Programme Officer (SPO)
The SPO is an official of the national administration line ministry/agency in charge of the
technical implementation of the IPA projects in case where the CFCU is responsible for the
administrative and financial implementation.
The SPO will have an appropriate rank that allows him to report to political level and to
coordinate the project activities in the concerned directorates/departments/division. However
it may be the right of each Ministry/Agency to decide the appropriate level of the SPO that
suits the managerial culture of that Ministry. The SPO can delegate part of his responsibilities,
including the right of endorsement of documents, to a maximum of two officials.
Pursuant to article 75(3) of the IPA IR, PAO shall designate officials within the national
administration as SPOs. Under the overall responsibility of the PAO concerned, SPOs shall
carry out the following tasks:
                    (a)     be responsible for the technical aspect of the operations within line
                            ministries,
                    (b)     assist the PAO in the good and timely preparation and
                            implementation of operations at technical level,
                    (c)     be in charge of the coordination within each priority axis set down
                            in the beneficiary country‟s project proposal.




                                             - 21 -
                           Programme Implementation Manual (PIM)


Briefly, the SPO is in charge of the technical implementation of the projects in accordance
with PRAG rules, regulations and procedures and ensures the technical support and expertise
necessary for effective and efficient project implementation.
The SPO chairs the Project Steering Committee.

 3.2.8. Transition Assistance and Institution Building Committee (TAIB Committee)
A committee, consisting of the NAO, NIPAC, PAO where appropriate representatives of
other OS, International Financial Institutions, Civil Society and the representatives of the
Commission, in charge of the monitoring of EU funded programmes in the Component-I.
TAIB Committee which is chaired by the NIPAC, meets at least twice a year at the initiative
of Turkey or EC.




                                            - 22 -
                                                                                    Programme Implementation Manual (PIM)                                                                       Figure 3
                                                                                                                                                                                              Inter Institutional Chart

                                                                CAO


                                                                NAO                                                            NIPAC                                             Strategic
                                                                                                                                                                             Coordinator (SC)
EC Headquarters/Brussels




                                                                                                                                                                             for Reg. Dev. &
                                                                                                                                                                                   HRD
                                                           NATIONAL                                                             EUSG                                          State Planning
                                                             FUND                                                                                                              Organisation


                                                                                                                                                                                                                        IPA
                           EC DELEGATION/ ANKARA




                                                                                                                                                                                                                     MONITORING
                                                                                                               OPERATING STRUCTURES
                                                            [Components I, (II), III and




                                                                                                                                                                                                                     COMMITTEE




                                                                                                                                                Ministry of Transport




                                                                                                                                                                        and Social Security
                                                                                                                         Ministry of Industry




                                                                                                                                                                        [Component HRD]
                                                                                                                                                                         Ministry of Labour
                                                                                                                                                 Competitiveness]
                                                                                                       Environment and




                                                                                                                                                  [sub-component
                                                                                                                          Competitiveness
                                                                                                       [sub-component




                                                                                                                          [sub-component
                                                                                                         Environment]
                                                                                                                                                                                                                    Component I – TAIB




                                                                                                                             and Trade
                                                                                                          Ministry of




                                                                                                                                                     Transport]
                                                                    CFCU




                                                                                                                              Regional
                                                                                                           Forestry
                                                                     IV]




                                                                                                                                                                                                                    Monitoring Committee


                                                                                                                                                                                                                   Component II - Sectoral
                                                                                                                                                                                                                   Monitoring Committee


                                                                                                                                                                                                                   Component III - Sectoral
                                                                                                                                                                                                                    Monitoring Committee
                                                                                                                Delegated bodies at local / regional level
                                                                                                                                                                                                                   Component IV - Sectoral
                                                                                                                                                                                                                    Monitoring Committee
                                                   Information                                                    Contractors / Beneficiaries of grants
                                                   Funds




                                                                                                                               - 23 -
                           Programme Implementation Manual (PIM)




4. Role of the SPO and the Project Team

4.1 Mission

The mission of the SPO and Project Team is to ensure an efficient and effective use of EU
and Turkish Government co-financing funds with the aim of achieving the set project
objectives and ultimately the expected impact in relation to the harmonisation process and
economic development of the country.


4.2 Scope of Work

The scope of work is to ensure a proper project administrative management and technical
implementation in all phase of PCM and in relation to the different project typologies and
associated instruments/contracts. This means that the SPO must assist in project
identification, in the management and monitoring of projects and finally in the evaluation of
implemented projects. The SPO is also responsible for ensuring that risks to project
implementation are minimised and that the project team is adequate for the tasks to be carried
out and operates to the highest ethical standards.

 4.2.1. Implementing Agreements – Operational Agreement
4.2.1.1 National Fund (NF)- CFCU

The NF and the CFCU establish an “Implementing Agreement” for each IPA Programme,
describing inter alia:
            1. the roles and responsibilities of the CFCU
            2. the procedures of transfer and the methods for utilisation of the funds
               allocated to the programme
            3. co-financing requirements
            4. financial control mechanisms
            5. the management of bank accounts, etc
Annexes to the Implementing Agreement include the relevant National Programme and
Council Regulation (EC) No. 1085/2006 establishing IPA both of which form an integral part
of the Agreement.




                                              - 24 -
                            Programme Implementation Manual (PIM)


4.2.1.2 CFCU - SPO
The CFCU in turn signs an Operational Agreement with the SPO for the division of roles and
responsibilities in implementation of specified projects. A template of the Operational
Agreement is at Appendix 1.
Article 6 of the Operational Agreement lists the SPO responsibilities as follows: -
       a. Preparation of ToR/TS and Works designs,
       b. Submission of requests to the CFCU to launch tenders,
       c. Providing necessary information concerning technical aspects of the project to the
           CFCU during the preparation of tenders and/or the tendering process,
       d. Endorsement of commitment and disbursement schedules prior to their
           transmission to the CFCU,
       e. Proposing voting members in Evaluation Committees and in Short List Panels,
       f. Provision of TA to the CFCU in contract negotiations, if necessary,
       g. Signing of Twinning Contracts, where appropriate,
       h. Technical management and monitoring of service, supply and works contracts of
           the programme/project, notifying the CFCU of difficulties or non-performance
           during contract implementation,
       i. Monitoring of grant contracts of grant beneficiaries in collaboration with relevant
           central and local authorities
       j. Contribution to the development and implementation of policies that facilitate the
           achievement of the project goals as well as the efficiency of future programmes
           and projects,
       k. Technical implementation of the EU-funded projects except the projects of grant
           beneficiaries:
                     Cooperating with the contractor and rendering logistical or other
                       assistance, if deemed necessary by SPO, ensuring that the
                       contractor performs the tasks in accordance with the pre-defined
                       deadlines and to the standard of quality required,
                     Approval of the reports of contractors (read and approved)
                     Ensuring that the provisional and final acceptances are properly
                       made



                                             - 25 -
                         Programme Implementation Manual (PIM)


                   Approval of experts‟ timesheets (read and approved),
                   Approval of technical documents and payments requests/invoices
                      prior to financial check and payment by CFCU (read and
                      approved),
                   Coordination with other departments within his/her Ministry or
                      Agency for the development and proper implementation of
                      projects,
       l. Preparation of regular status reports on the progress of the implementation of
          projects and input into the preparation of financial and reporting documents
          required by the CFCU,
       m. The immediate reporting of any determined/suspicious irregularity to the CFCU
          and, where non detected, the preparation and submission of a monthly “Zero
          Irregularity Report” to the CFCU,
       n. Participation in regular programme implementation and monitoring meetings with
          the CFCU and the ECD,
       o. Monitoring of the implementation of programmes/projects
                   Preparation of the Monitoring Report (MR)(semi-annually)
                   Participation in the appropriate Sectoral Monitoring Sub-
                      Committees (SMSC)
       p. Other tasks related to the technical implementation of the programmes/projects
          under his/her responsibility.


4.3 Project Development

The implementation of assistance under IPA is ensured through annual or multi-annual
programmes, as specified in the Commission Regulation on Implementation of IPA. All
programmes are designed following MIPD, a three-year strategy document for each country,
where the major areas of intervention and the main priorities are presented by the
Commission.




                                          - 26 -
                                Programme Implementation Manual (PIM)


 4.3.1. Financing Procedures
                                   Table 2 - Project Financing Procedure

                                       Activities                              Responsible body
              Approval of Financing Decision and related PFs by the IPA
              Committee and Financing Decision of the EC Transmission of        IPA Committee
              final version of FA to NIPAC
              Distribution of approved versions of PFs to the institutions
                                                                               NIPAC Secretariat
              and agencies and the members of FCC
              Transmission to the ECD of a confirmation letter for the
              availability of co-financing                                     NIPAC Secretariat
              After that NAO takes over the responsibility for co-financing.
                                                                                    NIPAC
              Signature of FA
                                                                                     EC

 4.3.2. Line Ministry or Agency Tasks and Responsibilities
The line Ministries and Agencies are not involved in the financing phase.

 4.3.3. Financing Agreement (FA)
The FA provides the legal basis for programme implementation and the programme is
implemented as set out in the PFs.
FA has a limited validity period, and the deadlines for commitments, execution of contracts
and disbursements are clearly stated within the FA. Amendments to the FA may be signed on
agreement of both parties. No contract can be signed until the FA has been signed by both
parties.
But however, in order to save time and not to experience last minute contracting, preparatory
activities with regard to implementation such as the drafting of implementation documents
(ToR, Contract Forecast, Procurement Notice etc.) should be started by the Beneficiary
Institution and the CFCU.

 4.3.4. Implementation Documents
In addition to approval of the NIPAC there are a number of documents that are needed before
implementation can commence, these include: -

            ToR for TA

            TS for supply of goods

            Guidelines for applicants for GS

            Contract for twinning programmes

            Detailed design for works




                                                      - 27 -
                                Programme Implementation Manual (PIM)



4.4 Project Identification

 4.4.1. Identification Procedures
                                    Table 3 - Project Identification Procedure

                       Activities                       Key documents            Responsible body
                                                   AP
         Identification of potential project       NPAA                          Line Ministry and
         ideas consistent with determined          Regular Reports                   Agencies
         priority areas                            Project idea descriptions
                                                   MIPD
                                                   AP                           Line Ministry and
                                                   NPAA)                            Agencies
         Discussion of project proposals with
                                                   Regular Reports              NIPAC Secretariat
         EC
                                                   Project idea descriptions          FCC
                                                   MIPD                             ECD, EC
                                                                                 Line Ministry and
                                                                                     Agencies
         Fine-tuning of the project proposals       IPA Programming Guide        NIPAC Secretariat
                                                                                       FCC
                                                                                       ECD

 4.4.2. Line Ministry or Agency Tasks and Responsibilities
The responsibilities and tasks of the Line Ministry or Agency in the identification phase are
as follows:

           The Minister or the Director General of the concerned agency appoints the
              programming coordinators (possibly he/she will be subsequently designated as
              SPO by the PAO).

           The Programming Coordinator participates at the meeting called by the NIPAC
              Secretariat to be informed on multi-annual objectives and priorities.

           The Programming Coordinator establishes the Programming Committee and
              appoints its members. The members should be selected among senior staff of
              the Ministry and key experts on harmonisation issues.

           The Programming Coordinator appoints a permanent technical secretary of the
              Programming Committee.
The Programming Committee meets and develops project ideas, on the basis of:

           Information on objectives and priorities provided by the NIPAC Secretariat and

           Analysis of key programming documents: AP, NPAA and Regular Reports
The technical secretary coordinates a technical team responsible for the preparation of short
descriptions of project ideas.




                                                      - 28 -
                               Programme Implementation Manual (PIM)


The Programming Coordinator participates in the discussion of project proposals with EC and
key DIS programming bodies (NIPAC, FCC, and ECD) to select and fine-tune the projects
ideas.
During this phase, the Programming Coordinators provide feedback to the technical team to
adapt project ideas to requirements.

 4.4.3. Co-financing
During this phase, the SPO is also responsible for ensuring the commitment of funds from the
National Budget in case a national contribution (co-financing) is required for the
implementation of the project. To this aim, the SPO will submit a request for fund allocation
and will co-ordinate with the FCC and MoF to make sure that the budget allocation will be
properly finalised. Following table gives the current co-finance ratios for the IPA
programmes under the Component-I.

                                           Table 4 - Co-finance Ratios

                COMPONENT TYPE                                           NATIONAL PUBLIC
                                                      EU
                                                                          CONTRIBUTION
                                                 CONTRIBUTION
              Direct Agreement*                         95%                    5%
              Twinning                                  95%                    5%
              Service (Institutional Building)          90%                    10%
              Service (Investment Related)**            75%                    25%
              Supply                                    75%                    25%
              Works                                     75%                    25%


   *     In case of a private contribution (e.g. by the international organizations), the EU
   Contribution and National Public Contribution will be calculated over the budget
   decreased by the amount of the private contribution.

   ** Expenditure related to equipment (regulatory infrastructure or ESC-related) and to
   technical assistance supporting investment (e.g. feasibility study / supervision of works /
   technical specifications) is considered as investment support.


4.4.3.1 Co-Financing: background
There are two types of co-financing: parallel and joint co-financing.
Under parallel co-financing, the project is broken down into clearly identifiable sub-projects
which are each funded by the different co-financing partners.


                                                     - 29 -
                                Programme Implementation Manual (PIM)


Under joint co-financing, the total project cost is divided between the co-financing partners
and all the funds are pooled such that the source of funding for a specific activity within the
project cannot be identified.
As a general rule, all investments must be co-financed. Co-financing amounts are shown in
the PFs annexed to the respective FAs.
Any project involving the direct agreement, twinning, service, supply of equipment and
works requires national co-financing in a range of 5%-25% of total eligible expenditure under
the relevant project. If the total cost of equipment and works is less than the amount
envisaged in the PFs, the amount of the EU assistance may be reduced to maintain the
maximum proportion of EU contribution to 75%. If the total cost is greater than the amount
envisaged in the PF, the extra support required will be principally provided by additional co-
financing of the beneficiary institution.


4.5 Project Formulation

 4.5.1. Formulation Procedures
                                    Table 5 – Project Formulation Process

                       Activities                           Responsible body            Deadlines
       Preparation of PFs                               Line Ministries and Agencies
       Meetings with ECD and Commission                 Line Ministries and Agencies
       services to assess projects maturity level     NIPAC Secretariat, FCC, ECD, EC
       PFs delivered by Line Ministries or Agencies
                                                        Line Ministries and Agencies    Mid of April
       to NIPAC
       PFs reviewed for compliance check by EUSG
                                                          EUSG and/or TA, CFCU
       and/or TA, CFCU
       Preparation of Annual Planning Document
                                                                   ECD
       (APD)
       Control of PFs by the
                                                                    EC
       EC services

 4.5.2. Line Ministry or Agency Tasks and Responsibilities
The responsibilities and tasks of the Line Ministry or Agency in the formulation phase
concern mainly the preparation and the revision process of the PF.
At this stage the:

            SPO should be nominated by the Line Ministry or Agency

            SPO has to appoint the members of the technical working group responsible for
               the preparation of PFs.
The members will be selected on the basis of:

            Technical background in project concerned technical fields and


                                                      - 30 -
                           Programme Implementation Manual (PIM)


           Project management experience

 4.5.3. The Project Fiche (PF)
The PF links the strategic documents such as the NPAA, MIPD and National Policy
Documents with the development of a specific project to achieve some specified objectives to
support the strategy.
The PF is a technical document that:

           Defines the typology of sub-projects and associated instruments (TA, Twinning,
              Supply, Works and Grant) to be implemented

           Defines the objectives of the project

           Describes the present situation in the concerned sector and identifies the issues
              that the project is aimed at addressing

           Describes the projects and its components

           Identifies the activities to be implemented

           Defines the institutional framework and the project management structure

           Identifies inputs requirements and the concerned budget
A PF template and guidelines are attached in Appendix 5. Concerning the formulation of PFs
there are two options:
          1. The Line Ministry or Agency formulates the PF relying on its in-house
              resources
          2. The Line Ministry or Agency asks for assistance from expert(s) recruited
              through the Framework Contract (FWC – see Section 5.4).
It is recommended to use FWC service at least the first time the Line Ministry or Agency is
engaged in the preparation of PFs.
To properly prepare PFs, read Section 5.3 on "Understanding the Logical Framework" and
reflect in particular on the following points:

           The project strategy must be formulated on the basis of sound and thorough
              analysis aimed at identifying the issues to be addressed to achieve project
              objectives, the actions to be implemented and the inputs required

           This analytical work should include the:




                                                 - 31 -
                           Programme Implementation Manual (PIM)


                  Identification of project stakeholders that are all institutions, social
                    and economic groups, individuals, private businesses that are
                    affected by the project implementation
                  The involvement of stake holders in the formulation of project
                    strategy to make sure that it will produce the desired impact and
                    benefits

           The PF must include a clear identification of the project management and
             technical structure including working groups and grant teams to be established
             and their composition.

4.6 Types of Institution Building Projects
 4.6.1. Technical Assistance (TA)
The TA is a service awarded to a Consultant to be selected through a competitive tender
process. The scope of the services is to transfer skills and technologies required for the
implementation of IB actions (preparation of a new law/regulation, reorganization of a
service, training, etc.) The scope of the service is defined within the ToR. The selection of the
Consultant is based on the evaluation of:

           Technical proposal (how the Consultant intends to implement the service)

           Expert(s) Curriculum Vitae (CV)

           Financial proposal (the proposed price of the services)

4.6.1.1 ToR for TA
The ToR, as a legally binding document, is part of the tender dossier. The ToR defines the
terms of the service that must be provided by the Consultant. The ToR for TA:

           Provides background information

           Defines the overall and specific objectives and the result to be achieved

           Identifies assumptions and risks

           Defines the scope of work

           Defines the specific activities to be implemented

           Defines the project management structure

           Defines logistic and timing

           Defines the requirements in terms of personnel and other inputs



                                             - 32 -
                                 Programme Implementation Manual (PIM)


           Defines reporting system

           Defines monitoring and evaluation arrangements

           Defines Visibility Rules

4.6.1.2 ToR preparation procedures

                                     Table 6 - ToR Preparation Procedure
                                                                                   Responsible
                               Activities                       Key documents
                                                                                      body
                       Preparation of draft ToR                   Draft ToR           SPO
                   Draft ToR delivered to the CFCU                Draft ToR           SPO
                   In order to ensure for compliance
                                                                                     CFCU
              administrative and technical standards ToR
                                                            Draft ToR / Draft TD     ECD
               reviewed by CFCU, included into TD and
                                                                                      SPO
                              sent to ECD.
               Conclusion of final version of ToR on the
                                                                   ToR/TD             SPO
                      basis of comments received
              Final version of ToR within the TD (see F.7                            CFCU
                                                                     TD
               Tendering Procedures) submitted to ECD                                ECD

Concerning the preparation of ToR for the TA there are two options:
                1. The Line Ministry or Agency prepares the ToR relaying on its in-house
                     resources
                2. The Line Ministry or Agency asks for assistance from expert(s) recruited
                     through the FWC,
It is recommended to use FWC service at least the first time the Line Ministry or Agency is
engaged in the preparation of ToR. In this case, see Section 5.4 to learn how to handle FWC
procedures.

 4.6.2. Standard Twinning
Twinning is a partnership between a Turkish public institution and a similar EU MS public
institution. The scope of the twinning is to:

                     Transfer skills and technicalities required for the implementation of IB
                       actions arising from the adoption of the Acquis Communautaire
                       (preparation of a new law/regulation, reorganisation of a service, training,
                       etc.)

                     Promote a long-lasting partnership between the twinned institutions (after
                       the end of the twinning project)
Twinning involves the secondment of long-term Resident Twinning Advisors (RTA) and
short-term experts from MSs Institutions to Turkish institutions.



                                                       - 33 -
                                  Programme Implementation Manual (PIM)


Every Twinning project has to include a MS Project Leader who continues to work in
his/her MS institutions but devote some of his/her time to conceiving, supervising and co-
ordinating the overall thrust of the project and a BC Project Leader. The Turkish partner
institution has to also appoint a RTA counterpart.
For the sake of coordination for twinning projects, National Contact Points (NCPs) are
established in both EU MS and in the BC. In the BC, the NIPAC plays the role of NCP. The
NCPs are the central point of communication between the Commission and the MS/BC
institutions.
The scope of Twinning is defined in the PFs which are circulated simultaneously in all EU
MS via the MS NCPs. The MS NCPs have the responsibility for channelling information to
MS Ministry and other relevant bodies and advising them on the process and development of
Twinning projects. The Turkish partner and the selected MS partner finally meet to prepare
the Twinning Contract.

 4.6.3. Twinning Contract
The Twinning Contract can be equated to a contract between the two partner institutions, by
which each partner undertakes to fulfil specific tasks and obligations. The contract defines
expected results, sets the “mandatory results”, identifies and plans the activities to be
implemented, including the implementation time schedule, analyses risks, defines the budget
and includes the entire necessary annex adhering to the standard contract template.

 4.6.4. Standard Twinning Preparation Procedures
                                    Table 7 - Twinning Preparation Procedure

                     Activities                     Key documents           Responsible body         Deadlines
   Circulation of PFs to MS via NCPs              Call for Proposal (PF)          EC BXL              8 weeks
   NCPs channel information to MS Ministry
                                                  Call for Proposal (PF)         MS NCP
   and other relevant bodies
                                                                            EU Member States
   Submission of proposals                          written proposal
                                                                               Institutions
   Delivery of the proposals to Turkish
                                                    written proposals        BC NCP (EUSG)
   Beneficiaries
                                                                                   CFCU
   Organization and co-chairing of Selection        written proposal
                                                                                   EUSG
   Meeting                                          oral presentation
   Selection of the MS partner                     Selection Fact Sheet              BC               2 weeks
                                                                              BC NCP (EUSG)
   Selection Report including selection fact                                  following official
                                                    Selection Report
   sheets                                                                  approval of the CFCU
                                                                           to the Selection Report
   Notification of selection results                                           BC NCP(EUSG)
   Preparation of Twinning Contract and draft
                                                 Draft Twinning Contract     Twinning partners       3 months
   delivered to ECD ,CFCU and EUSG
                                                                                    ECD
   Assessment of the draft Twinning Contract     Draft Twinning Contract           CFCU               4 weeks
                                                                                   EUSG




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                                  Programme Implementation Manual (PIM)


                                                   Consolidated comments of
                                                    CFCU, EUSG and ECD
  Submission of consolidated comments                                              CFCU
                                                      based on in depth
                                                         assessments
  Preparation of revised version on the basis of    Revised draft Twinning
                                                                              Twinning partners
  consolidated comments                                    Contract
  Acceptance and operational and
                                                    Revised draft Twinning
  financial/legal check of revised draft and                                       CFCU
                                                           Contract
  delivery to ECD
  Operational and financial/legal check;
  submission of final draft contract to EC
                                                      Twinning Contract             ECD
  Steering Committee in BXL with
  recommendation for opinion
  Verification of conditionalities (if any);
  submission of final Twinning Contract to                                    CFCU and EUSG
  ECD
  Once finally approved the Contract has to be
  signed by the representatives of partner            Twinning Contract       Twinning partners
  institutions
  Submission of the hard copies to CFCU for
                                                      Twinning Contract       Twinning partners
  signature
  Submission of the hard copies to ECD for
                                                      Twinning Contract            CFCU
  endorsement
  Notification of the Twinning Contract                Notification letter         CFCU

 4.6.5. Twinning Light
Twinning Light is an instrument that can be used to address any self-contained institutional
issues with a limited scope than for standard twinning, i.e. the structures needed are not
complex or the existing ones need little adjustment.
Twinning Light consists of the provision by a MS institution of a package of services,
generally involving the short-term or medium-term missions by selected MS officials. In
other words, the relation existing between standard and Twinning Light can be compared to
the one existing between TA and FWC.
The financial ceiling for “Twinning Light” projects has been set at €250.000 and their
maximum duration limited to 6 months. In exceptional cases, this can be extended to 8
months. This duration is supplemented by the standard 3 months period foreseen for
inception and reporting. Apart from these ceilings, the absence of RTA and the absence of
“jointly prepared work plan” are the main differences between a standard twinning and a
twinning light project.
All of these distinguishing factors underscore that “Twinning Light” project must allow for a
quick mobilisation of targeted public sector assistance.
The beneficiary should complete a detailed PF. Due to the absence of jointly prepared work
plan the PF has to be precisely very well defined. As a rule, the Twinning Light project
should be included in the country‟s annual programming exercise but they can also be
initiated in the interim between two exercises.



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The scope of Twinning is defined in the PF which is circulated simultaneously in all EU
Member States via the MS National Contact Points.

4.6.5.1 Twinning Light ToR
The BC should complete a “Twinning Light” PF as per the template provided in Annex- C1
of the relevant Twinning manual by containing:

                     a detailed description of the beneficiary institution,

                     the objectives of the service

                     the nature of the activities

                     the mandatory results it wishes to target, including the benchmarks)

                     the profile of the expert(s) required

                     the location and duration of the assignment

                     the total available budget

                     the inputs it is seeking from a MS and the amount of funds it wishes to
                        use for that purpose;

4.6.5.2 Twinning Light preparation procedures

                                Table 8 - Twinning Light Preparation Procedure
                                                                           Responsible
                     Activities                    Key documents                                Deadlines
                                                                              body
     PF Prepared by concerned beneficiary
                                                           PF              Line Ministry
     institution
     Assessment of PF and send to ECD for
                                                           PF               CFCU-ECD
     opinion
     Distribution of PF                                    PF                 CFCU
     NCPs channel information to MS Ministry
                                                           PF                MS NCPs
     and other relevant bodies
     Proposal (name of Project Leader, CV of
     proposed officials and budget) prepared by                               EU MS
                                                    Written Proposal                             Six weeks
     interested EU MS institutions and sent to                              institutions
     Turkish institutions
     Submission of proposals to Beneficiary
                                                    Written Proposal      EUSG-BC NCP
     Institution
                                                                                CFCU
     The CFCU will set up a selection
                                                                           Representatives
     committee and chairs the selection
                                                                            of beneficiary
     meeting. The beneficiary, EUSG, and            Written Proposal
                                                                              institution
     ECD must be represented in the selection
                                                                          EUSG (observer)
     committee, the latter two as observers
                                                                           ECD (observer)
     In case of a need for clarification, the
                                                    Proposal and BC
     requests for clarification /                                            EU MSs          maximum of 5 WDs
                                                       request for
     Correction will be made in writing and the                             institutions
                                                      clarification
     MS will provide a reply.
                                                                                             Max. six weeks of
                                                                              CFCU            the deadline for
     Notification of selection results            Selection Fact Sheets
                                                                                               submission of
                                                                                                 proposals



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5. Importance of Starting Implementation Actions
       Early


5.1 Last Minute Contracting
Many projects suffer from implementation delays leading to last minute contracting of
services, works and supplies and this severely damages the efficiency of implementation. For
example, after a contract is signed it sometimes happens that the contractor will request a
change of key personnel3. If there is severe time constraints the Contracting Authority may
have little option but to agree to a change, in circumstances where it would prefer to re-tender
the project.
For efficient and satisfactory project implementation, it is necessary to recognise the
importance of the time limits that apply to all IPA co-financed projects and the delays that
can occur prior to signature of contract for project implementation.

    5.1.1. Time Scheduling Diagram for a Service Contract >€200,000.
Table 9 and Figure 4 show the shortest possible time periods that may be involved in a
service tender. Please note the comment “shortest possible” because time periods will
frequently be longer. Also note that the period shown applies after ToR have been approved.
                                  Table 9 - Contracting Process timescales*

                  Stage    Time period applying to the Contracting Process          Calendar
                                               Stage                                 Days
                    1      Contract Forecast                                           30
                    2      Procurement Notice                                          30
                    3      Approval of Shortlist                                        7
                    4      Invitation to Tender                                        50
                    5      Approval and confirmation of successful Tenderer            15
                    6      Signature                                                    5
                                                             Total Calendar Days      137
                                                                            Weeks      20
                                           * For a Service Contract > €200,000


    5.1.2. Time Schedule and FA Time Limits
The activities shown in Table 9 take place after the signature of the FA. Therefore they start
up using the implementation period. If the SPO delays the preparation of ToR/TS until after


3
  This is the actual experience of many SPOs and it is suspected that some Contractors use attractive CVs simply
to win a project.


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                                 Programme Implementation Manual (PIM)


the signature of the FA then that preparation time will further spend from the implementation
period. Figure 4 shows the FA deadlines: -

                                          Figure 4: FA Timescales

                                                                                 Disbursement time limit 3 years -
                                              Contracting time limit 2 years -
    - Signature of Financing Agreement


                                                             Maximum Available Implementation period


                      Maximum Available contracting period




Take an extreme example. If it took 12 months to get approved ToR this 12 months would
reduce the maximum available implementation from 36 to 24 months and the 22-week
contracting period would reduce the 24-month period further.

It is essential therefore that SPOs and prospective SPOs, regardless of signature of the FA,
should start preparing the implementation documents immediately where necessary use
guideline (Appendix 6) for TS during preparation exercise and submit to the CFCU.
If time, human resources or expertise is not available to the SPO then a FWC should be
used to progress matters.
There is however a provision that a tender may be launched with a suspension clause in
anticipation of the signature of the FA.


5.2 Assessing the Quality of a Project Proposal

It is essential to plan projects carefully and comprehensively so that implementation is most
effective. There are a number of criteria that are possible for checking the quality of a project
proposal. The following Quality Assessment Parameters provide a key for areas of careful
attention at the project definition stage.

 5.2.1. Relevancy
                 1. Are the beneficiaries clearly identified?
                 2. Are the problems of the beneficiaries described sufficiently?
                 3. Is the problem analysis sufficiently comprehensive?
                 4. Do the Overall Objectives explain why the project is important for society?


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              5. Is the Project Purpose defined in terms of benefits to the beneficiaries?
              6. Has the need for the results been demonstrated?

 5.2.2. Feasibility
              7. Will the Project Purpose contribute to the Overall Objectives (if the
                  assumptions hold)?
              8. Are the Results described as services to be delivered to the target group?
              9. Will the Project Purpose be achieved if the Results were delivered?
              10. Are the means sufficiently justified by quantified objectives
              11. Have important external conditions been identified?
              12. Is the probability of realisation of the assumptions acceptable?
              13. Will beneficiary be able to implement the project?

 5.2.3. Sustainability
              14. Will the relevant authorities have a supportive policy after the project has
                  ended?
              15. Is the technology appropriate for the local conditions?
              16. Will the ecological environment be preserved during and after the project?
              17. Will there be adequate ownership of the project by the beneficiaries?
              18. Will women (and other groups) have adequate access to benefits and
                  production factors during and after the project?
              19. Will beneficiary be able to provide follow-up after the project?
              20. Does the financial and economic analysis confirm that the “incremental
                  project” is efficient, effective, viable and relevant?


5.3 Understanding the Logical Framework

 5.3.1. The Logframe
The logframe should be seen as a way of thinking and also be seen as a dynamic tool, which
should be re-assessed and revised as the project itself develops and circumstances change. It
should be used to provide structure and purpose to project planning and budgeting without
being perceived as an inflexible and constraining blueprint.




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By bringing stakeholders together during the analysis phase, to discuss problems, objectives
and strategies, the logframe approach encourages people to consider what their own
expectations are, and how these might be achieved.
By stating objectives clearly and setting them out in a “hierarchy of objectives”, it then
provides a means of checking the internal logic of the project plan, ensuring that activities,
results and objectives are linked.
Planners are forced to identify the critical assumptions and risks that may affect project
feasibility, and to specify the indicators and sources of information that will be used to
monitor and evaluate the project. All of this key information is brought together in one
document that provides a useful summary.
The logframe itself (Figure 5) consists of a table, or matrix, which has four columns and (in
its most basic form) four rows. The vertical logic identifies what the project intends to do,
clarifies the causal relationships and specifies the important assumptions and uncertainties
beyond the project manager's control. The horizontal logic relates to the measurement of the
effects of, and resources used by, the project through the specification of key indicators of
measurement, and the means by which the measurement will be verified.
                               Figure 5: Logframe structure




 5.3.2. Intervention Logic
The strategy underlying the project is called the intervention logic. It is the narrative
description of the project at each of the four levels of the hierarchy of intervention used in the
logframe.




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 5.3.3. Specifying Assumptions/ Risks
Often a project‟s success depends not only on project‟s interventions, but also on external
factors or specific assumptions. External factors can be identified by brainstorming for each
level of the logframe.

 5.3.4. Factors Ensuring Sustainability
Factors ensuring sustainability should also be included in the logframe. A project can be said
to be sustainable when it continues to deliver benefits to the project beneficiaries for an
extended period after the main part of the donor assistance has been completed.

 5.3.5. Analysis of Factors Affecting Sustainability
A project can be said to be sustainable when it continues to deliver benefits to the project
beneficiaries. Two tools can be used to help assess the internal and external factors directly
affecting the project. These are the SWOT (Strengths, Weaknesses, Opportunities and
Threats analysis) and the SEPT (Social, Economic, Political and Technological) analysis.

 5.3.6. Objectively Verifiable Indicators
Objectively Verifiable Indicators are measurable indicators that will show whether or not
objectives have been achieved at each level of the logframe hierarchy. Objectively Verifiable
Indicators provide the basis for designing an appropriate monitoring system.
“Objectively verifiable” means that different people measuring the same indicators obtains
the same measurements.

 5.3.7. Means of Verification
Means of Verification are the means by which the indicators or milestones will be recorded
and made available to project management or those evaluating performance. The Means of
Verification should specify: the format, who should provide information and how regularly
should it be provided.

 5.3.8. Means and Costs
Means are the human, material and financial resources required to undertake the planned
activities and manage the project. In order to provide an accurate estimate of the means and
costs required for a project, planned activities and management support activities must be
specified in detail.




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                          Programme Implementation Manual (PIM)



5.4 Framework Contracts
The FWC is a facility that allows for the recruitment of experts to assist Turkish authorities
during the implementation of PCM. Its maximum budget ceiling is €200,000 and the
maximum duration of the service is 12 months. The TA service is awarded to a consortium
(composed of several consulting companies) to be selected through a competitive tender
process from the longlist of the FWC companies on a rotational basis. The selection criteria
are based on the evaluation of expert(s) CV.
Appendix 7: Guide for FWC and template tells more about FWC and how to manage it.

 5.4.1. FWC Service Mobilization
To mobilize assistance from FWC the SPO with the support of the working group has to:

           prepare the ToR and related budget estimate for the FWC expert(s)

           Deliver the ToR and the Requests for Services to the CFCU that is responsible
             for the implementation of tendering and contracting procedures

 5.4.2. FWC ToR
The ToR, as a legally binding document, is part of the offer for services. The ToR defines the
terms of the service that must be provided by the Consultant. The ToR for FWC:

           Provides background information

           Defines the objectives of the service

           Describes the requested services

           Defines the expected results of the services (in terms of outputs to be produced)

           Defines the profile of the expert(s)

           Defines the location and duration of the assignment

           Defines reports to be produced by the expert(s)
The ToR should not be longer than about ten pages according to the FWC Guide.

 5.4.3. Role of SPO
           The SPO has to propose two members of the evaluation committee from the
             members of the technical working group. The composition of the Evaluation
             Committee is approved by the CFCU and sent to the ECD for ex-ante control.
The SPO, upon FWC experts‟ arrival in Turkey, has to:



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               Programme Implementation Manual (PIM)


 Brief them and make sure that they are briefed by the CFCU.

 Make sure that they work in close collaboration with the technical working
  group

 Monitor their performance




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6. Management, Monitoring and Evaluation of
       Assistance and Record Keeping

6.1 The Project Steering Committee
Section 4.3 of the standard ToR describes the arrangements for management of the project.
Usually (and desirably) the ToR provides for a Steering Committee that shall be chaired by
the SPO.
Section 8 of the standard ToR also provides details of Monitoring and Evaluation
arrangements; it should describe Objectively Verifiable Indicators of outputs expected under
the project.
The most important project management and monitoring meeting is the Project Steering
Committee. Chaired by the SPO and involving ECD (as observer) and CFCU, Project
Consultant and the SPO project team members, the project Steering Committee is the last
word on monitoring of technical implementation questions. The Steering Committee should
play a key role in project implementation. All key stakeholders are represented and the
approval by the Steering Committee4 of Consultant‟s reports is the most important
record/indicator of the technical implementation of the project.
There should be no loss of focus on the role of the Project Steering Committee as the
lynchpin of management and monitoring of implementation. Any meetings which compete
with or distract from the role of the Project Steering Committee should be abolished.
Meetings convened for other purposes such as Project Planning meetings should be named
correctly to avoid confusion as to the proper content of the agenda.
It is sometimes overlooked that the contract with the consultant comprises not only the ToR
but also the consultant‟s technical proposal. These two documents are usually combined in
the Inception Report which should detail the project implementation plan in all its aspects.
A key rule for dealing with Consultants is to get them to do the work.




4
    Countersigned by the SPO on the Report Cover sheet


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                             Programme Implementation Manual (PIM)



6.2 TAIB Committee meetings

The EC supervises the implementation of the programmes through its services in the DG
ELARG and Delegations in the countries. For this purpose, a monitoring system is
established which includes TAIB Committee between the EC and the beneficiary countries,
where the implementation of financial assistance programmes is discussed with the help of
monitoring and evaluation reports and where corrective actions are agreed upon as necessary.
Further monitoring takes place based on sectors as well as at the project level.
The TAIB Committee comprises representatives of the FCC and the EC. The Committee
meets at least twice a year to review the programmes. The following are the main tasks of the
TAIB Committee:

                    Assessment of the realisation of the targets set forth in the FA within the
                      scope of the MR.

                    Provide suggestions for: change in priorities, transfer of resources
                      between programmes and in cases of need also for additional financial
                      resources on a programme basis in order to be able to attain the set
                      targets.

                                                 Table 10 - Monitoring Procedure

                                                                                    Responsible
                         Activities                          Key documents
                                                                                       body
                                                                                   SPO and Project
                     Preparation of MR                            MR
                                                                                       Team
              Assessment of MR, formulation of
                                                             Recommendations           SMSCs
                     recommendations
                                                                                   SPO and Project
          Implementation of SMSCs‟ recommendations           Recommendations
                                                                                       Team



The purpose of the monitoring phase is to gather data on project progress, to assess the
likelihood of objectives being met and whenever necessary, to recommend changes.
The very first step begins with preparation of the MRs by the SPOs of the each sector or sub-
sector. These reports are sent to the NIPAC. The NIPAC forwards the reports to NF and
CFCU. These reports should report on project implementation and highlight any unusual
difficulties during the implementation phase. The Final Report of each project provides the
key source of input to the MR.
The second step is the meetings of the SMSC. Each SMSC works on the basis of MRs
prepared by the SPOs in each sector or sub-sector for which they are responsible. The MRs


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                              Programme Implementation Manual (PIM)


are presented by the NIPAC. Representatives from the NF and CFCU also participate in the
SMSCs meetings. SMSC takes into account any input from the ECD and EC services or from
other relevant sources. Each SMSC analyses programme and project design, efficiency,
effectiveness, impact and relevance by reviewing outputs as compared to objectives,
expenditure and the management structures of the programmes and projects. These latter
inputs are provided by the Interim Evaluation Team (IET), which undertakes sectoral
evaluations on a cyclical basis, based on direct discussions with the SPO and Project Team
(see more below under 6.3.1).
On the basis of this review, each SMSC addresses recommendations to the relevant parties
with the aim of ensuring the correct and most appropriate technical, contractual and financial
implementation of the activities. The relevant parties in accordance with regulations and rules
of procedure apply these recommendations, which are also submitted to the IET.
Any change that affects contractual provisions requires the preparation of an Addendum to
the Contract.


6.3 Project Evaluation

 6.3.1. Evaluation Procedures
                                      Table 11 - Evaluation Procedure
                                                                                    Responsible
                         Activities                       Key documents
                                                                                       body
           Preparation of Interim Evaluation Report    Interim Evaluation Report        IET
           SMSC meetings for Interim Evaluation
                                                       Interim Evaluation Report      SMSCs
           debriefing
           Transmission of SMSC MRs to the
                                                       Interim Evaluation Report       NIPAC
           NIPAC
           Assessment of MR, Formulation of
                                                          Recommendations          TAIB Committee
           recommendations
                                                                                    Implementing
           Implementation of TAIB Committee
                                                          Recommendations            Authorities/
           recommendations
                                                                                    Beneficiaries

The Interim Evaluation Report is prepared by the independent IET following procedures
similar to those described for the preparation of MRs.

The SMSCs produce summary reports for each sector, which will be submitted to the TAIB
Committee at its annual meeting by NIPAC. The SMSC provides any further information on
TAIB Committee‟s request.
In its bi-annual meetings, TAIB Committee reviews and assesses ongoing EU-funded
assistance programmes on the basis of a MR presented by the NIPAC together with a country
evaluation summary report prepared and presented by the IET. On the basis of these reviews


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and assessments, the TAIB Committee may propose corrective measures to be taken to
ensure the achievement of programme objectives and enhance the efficiency of the assistance
provided.
TAIB Committee recommendations are presented to the EC, to the NIPAC, to the NAO and
to the members of the FCC to take actions within the scope of their mandates. TAIB
Committee will be kept informed on the recommendations follow-up.

 6.3.2. SPO Role and Tasks
The SPO and Project Team play a limited role in the preparation of the Interim Evaluation
Report. The SPO should mainly:

                  Provide inputs to the IET for the preparation of the report

                  Ensure that evaluation recommendations and lessons learned are taken
                      into consideration during the next programming, identification an
                      formulation phases
However nothing prevents the Line Ministry/Agency to conduct its own internal evaluation
exercise.

 6.3.3. Evaluation Process and Methodology
Evaluation can take place:

                  When the project is still on-going – interim evaluation – mostly aimed at
                      re-addressing project strategy

                  On completion of the project        - end of project evaluation - mostly
                      aimed at verifying achievements in terms of specific objectives and
                      possible impact

                  After the completion of the project – ex-post evaluation – mostly aimed
                      at verifying impact and sustainability
From all types of evaluation should be learned lessons to apply in the next programming and
formulation phases.




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                                 Figure 6: Evaluation Process

                Project
              environment                                     RELEVANCE
                                                              AND
                                                              SUSTAINABILITY

                Wider Objective


                                                              IMPACT

               Specific Objectives



                                                              EFFECTIVENESS

                Expected Results
                   (outputs)



                   Activities

                                                              EFFICIENCY

                     Inputs




The evaluation includes five criteria:

                   Relevance

                   Efficiency

                   Effectiveness

                   Impact

                   Sustainability
The relevance criterion is to assess the extent to which the stated objectives correctly address
the identified problems or real needs and the appropriateness of project design.
The efficiency criterion is related to the process of transformation of inputs into outputs. It
answers to the following questions:



                                             - 48 -
                          Programme Implementation Manual (PIM)


                  Were the expected results achieved?

                  Were they achieved in the due time?

                  Were the planned inputs appropriate?

                  Were the resources used efficiently?

                  Were the costs consistent?

                  Were the activities implemented efficiently?

                  Was the project management efficient?

                  Was the overall aid system efficient?
The effectiveness criterion is to assess whether the expected results were effective and
appropriate to the achievement of project specific objectives. It answers to the following
questions:

                  Were the immediate objectives achieved?

                  Did the results achieve needed critical mass to put in motion changes?

                  Was the project flexible enough to adapt to changing environment?

                  Were the results internalized and adopted by the concerned National
                    Institutions? (In other words, do the concerned National Institutions fill
                    project ownership?)
The impact criterion is to assess whether the achievement of specific objectives contribute to
the achievement of the project wider objective.
The sustainability criterion is to assess whether the positive achievements in terms of
objectives are likely to continue after the external funding ends. Impact and sustainability
requires ownership from all project stakeholders, policy support, and institutional capacity
and management skills.


6.4 Checklist of Activities Required from SPO

 6.4.1. Planning, Identification and Formulation
                  Coordinate activities of the concerned departments/divisions related to
                    project planning, identification and formulation phases including the
                    preparation of PF.

                  Coordinate the planning committee



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                        Programme Implementation Manual (PIM)


               Whenever needed request FWC service

               Appoint members and coordinate the working group for the preparation
                of PF.

6.4.2. Implementation
 6.4.2.1    Preparation of project documents
               Whenever needed request FWC service

               Ensure     coordination of the concerned departments/divisions for the
                preparation of project document
                    ToR for TA
                    TS for supply of goods
                    Guidelines for applicants for GS
                    Contract for twinning programmes
                    Detailed design for works
               Appoint members of the concerned working groups

               Sign the twinning contract

 6.4.2.2    Tendering and contracting
              Submit request to the CFCU to launch tenders

               Provide information about technical aspect to the CFCU during the
                preparation of tender

               Assist the CFCU in the composition of the Evaluation Committee

               Assist the CFCU in contract negotiation

6.4.3. Project Technical and Administrative Management
 6.4.3.1   Actions common to all contract types
              Provide logistic support to TA team

               Ensure overall supervision of contractors

               Approve or endorse:
                     Contractors‟ reports
                     Time sheets
                     Provisional/final acceptance of goods
                     Contractors invoices/payment requests (read and approved)
               Prepare monthly reports and irregularity reports/zero irregularity reports

               Organize and coordinate working groups on IB issues



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             Distribution of technical documentation to Working Group members

             Drafting and circulate working groups minutes

             Follow-up working groups activities in the concerned departments
               ensuring that expected outputs are delivered in due time

             Liaise with HRD experts and departments to develop guidelines and
               training material for the implementation of the IB activities

             Organize related training courses, seminars, study tours and other
               activities aimed at the dissemination and implementation of results

             Take all needed action to maximize the project efficiency and
               effectiveness

             Supervise the project technical re-direction based on the TAIB/SMSC
               recommendations

6.4.3.2   Actions specific to GS management
             Set-up Grant Management Team at central regional and provincial level

             Drafting Guidelines for Applicants and call for proposal

             Prepare information campaign strategy and material

             Implement the information campaign

             Organize training for regional and provincial staff

             Organize training courses for potential beneficiaries

             Organize a helpdesk to provide assistance to potential beneficiaries for
               the preparation of proposals and for grant administration and reporting

             Develop and update database that includes all information on grants at
               their different implementation stages

             Supervise the activities of regional and provincial teams

             Provide answers to beneficiaries enquiring

             Forward potential beneficiaries‟ questions to the CFCU whenever
               required and return the answer to beneficiaries

             Make regular monitoring visits and on-the-spot-checks

6.4.3.3   Monitoring
            Participate to SMSC



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                 Prepare six month MRs

                 Provide feed-back to senior management on:
                            Implementation efficiency
                            Programme achievements
                            Constraints affecting achievements
                            Suggestions and recommendations to overcome constraints
                            Programme impact on harmonisation process
 6.4.3.4     Evaluation
                Contribute to preparation of evaluation reports in accordance with the
                   EC procedures

                 Make sure that all necessary collaboration is offered to the IET

                 Implement internal evaluation

                 Provide inputs to next programming, identification and formulation
                   phases on the basis of lesson learned during the implementation of
                   monitoring and evaluation exercises

                 Provide feed-back on project performance and achievements to political
                   levels

 6.4.3.5    Working groups
     Working groups will be set up for implementing specific functions related to different
    phases of the project cycle, such as:

                 Formulation phase - preparation of PF

                 Implementation phase - preparation of project technical documentation:
                      ToR for TA
                      TS for supply of goods
                      Contract for twinning programmes
                      Detailed design for works
                 Implementation phase – coordination of activities of concerned
                   department/divisions for the implementation of the IB activities


6.5 Checklist for Regular meetings

6.5.1. Sectoral Monitoring Sub-committees Meeting
 6.5.1.1     Participants:
                NIPAC and ECD (co-chairs)



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               NF representative

               CFCU representative

               SPOs and project team members where necessary

 6.5.1.2   Scope:
              Reviewing project MRs and interim evaluation reports

               Make recommendations to improve project implementation

               Whenever necessary recommend re-direction of project activities

6.5.2. Steering Committee Meeting
 6.5.2.1   Participants:
              SPO (Chairs)

               Key Project Team members

               TA team leader /RTA and team members, if necessary

               Other stakeholders identified within the ToR

               CFCU

               ECD

 6.5.2.2   Scope:
              Assess project performance, achievements and constraints affecting
                performances

               Assess policy issues and adequacy of policy framework

               Provide feedback on impact on harmonization and/or economic
                development

6.5.3. TA Coordination Meeting
 6.5.3.1   Participants:
              SPO

               Programme manager

               Programme monitors/evaluators

               Programme technical coordinators

               Key staff of concerned technical departments

               TA team leader



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                    TA team members

  6.5.3.2       Scope:
                   Asses project performance and constraints affecting performances

                    Planning and organizing project activities

6.6 Publicity and Visibility
 6.6.1. Objective and EC Requirements
The main aims of the publicity / visibility requirements set by the EC are to:

                    Highlight the role of EC funding

                    Increase the public awareness and transparency over the activities co-
                      funded by the EC

                    Inform potential beneficiaries about the financing possibilities available
Thus, the EC requirements in relation to publicity and visibility shall be respected during the
implementation phase in relation to:

                    Information of potential beneficiaries (call for proposals)

                    Publicity and information over the tendering procedures to ensure the
                      transparency of selection of contractors

                    Application and documentation of visibility requirements
It is to be noted that “publicity” in this context does not include marketing activities.
The obligation for respecting the information and publicity requirements of the EU are set in:

                    The FWA

                    The FA
                   Publicity must be ensured in accordance with the applicable rules on the
                   visibility of external action laid down and published in the “EU guidelines on
                   visibility” available on:
                   http://ec.europa.eu/europeaid/work/visibility/index_en.htm
                   The standard formats to be used in briefings, newsletters, press conferences,
                   presentations, invitations, signs, commemorative plaques and all other items
                   used to highlight EU participation are described in the EU guidelines on
                   visibility. Electronic templates have been developed by the EC for each type of
                   communication tool and can be downloaded from this link.



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                   The use of these guidelines is compulsory for all contractors/consultants under
                   contracts and FAs which explicitly refer to them, whether signed by the EC or
                   by any other Contracting Authority. Their use is recommended for all other
                   contractors/consultants and/or implementing partners in fulfilling the visibility
                   requirements of actions funded by the EU. In all cases the provisions of specific
                   contracts and financing.
Failure to comply with EU visibility requirements will result in ineligibility of project costs in this
area. If the EU visibility rules are violated, costs for publications, seminars and conferences, etc.
may not be approved.
Any item co-funded by the EC (e.g. stationery, web site materials, reports, publication, signs
etc.) shall display the EU logo in accordance with the instructions for the reproduction of the
EU logo available on:
http://publications.eu.int/code/en/en-5000100.htm

 6.6.2. Tools
The key tools of information and communication are:

                    Media – press releases, press events, interviews, background papers,
                      project visits

                    Events – forums, information days, workshops, professional debates,
                      seminars, conferences, project presentations, other regional events
                   Publications – news letters, brochures, leaflets, project information sheets,
                   reports, studies, programme presentation summaries

                    Publications Internet pages

                    Others: billboards, plagues, stickers, flags, maps, posters and tableaux

 6.6.3. Communication Plan
The “Communication Plan” shall reflect the fact that the programme targets specific geographical
areas and/or target groups (as relevant) bearing in mind the different types of project promoters
that have relevance for the project implementation.
More precisely the “Communication Plan” shall include at least the following:
                   The aims of the programme and target groups;
                   The strategy and content of the information and publicity measures to be
                   implemented to inform the potential beneficiaries,


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                  The indicative budget for implementation of the “Communication Plan”;
                  The administrative departments or bodies responsible for implementation of the
                  information and publicity measures;
                  An indication of how the information and publicity measures are to be
                  evaluated in terms of visibility and awareness of SPO and of the role played by
                  the EC.
The SPO shall supervise “Communication Plan” prepared by the contractor to outline how
information and publicity measures will be undertaken including aims and target groups,
communication strategies, the budget and those responsible for the implementation. On that basis,
SPO shall provide the text in Appendix- 8 in ToR during preparation in tendering phase.


6.7 Record Keeping by the Project Team

 6.7.1. Filing
The establishment of efficient filing system and its subsequent accurate operations are
essential to successful project management since it creates adequate audit trails and facilitate
the easy retrieval of documents at any given point of time by any authorised person.

 6.7.2. Retention Policy
All documents relating to the Community assistance shall be kept for seven years after the
closure of the programmes.




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7. Risk Analysis
Risk management provides a framework to identify, assess and manage potential risks and a
way for managers to make informed management decisions.
A risk is something which could:

                      Prevent the achievement of the project objectives

                      Cause financial disadvantage, i.e. additional costs or loss of money or
                         assets,

                      Result in damage to the SPO reputation.


7.1 Sources of Risk

 7.1.1. External Risks
Inherent Risk arises when there are external forces that can affect an organisation's
performance or make its choices regarding its strategies, operations, external relationships,
organisational structure or financing obsolete or ineffective.
      Regulatory risks
                      Change in EU regulations,

                      Change in the Turkish regulations,

                      Change in the Turkish administration structure,

                      Change in internal regulations of any of the key players.
      Capital availability risks
                      Risk that the SPO may have an inadequate budget.

                      Risk that resources for ensuring co-financing are not available.

      DIS bodies performance risks

                      Poor working relationship or poor performance of DIS bodies
      Technological risks
                      Risk linked to the implementation / operating of hardware and software
      Catastrophic loss risks

                      Loosing paper files and records in the event of a fire or other disaster.




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 7.1.2. Process Risks
Control risk is the risk that SPOs systems are inadequate to ensure the EU and national
contributions are used economically and efficiently and for the purpose intended, and that the
use of funds is properly reported.
      Effectiveness risks
                      Inadequate policy framework

                      Poor project strategy

                      Poor design of PFs

                      Poor design of project documents

                      Poor monitoring and evaluation
      Efficiency risks
                      Inadequate development of PMG

                      Lack of established lines of authority

                      Inadequate management structure and job description

                      Inefficient procedures and processes

                      Poor reporting system

                      Inadequate Plan of Actions

                      Risk linked to late deployment of FWC, TA and late start of twinning
                         projects

                      Risk of delay in relation to procedures deadlines

                      Risk that external information/data are not received in due time

                      Inadequate IT development and lack of sensitive data protection
   Human resources risks
                      Employees do not have appropriate skills/qualifications

                      The number of employees is inadequate

                      Inadequate staff performance

                      Inadequate training contents and delivery methods
      Partner satisfaction risks
                      Poor working relationship or poor performance of TA team or twinning
                         partners

                      Poor working relationship or poor performance of technical departments


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                      Poor internal coordination/communication
      Irregularities and frauds risks
                      See Section 8.4


7.2 Develop a Risk Management Policy

The objective of the Risk Management Policy is to provide a sound basis for integrated risk
management and internal control.
An effective Risk Management policy should allow the SPO and Project Team to:

                      Achieve its mission by objectives

                      Implement an early warning system of potential problems

                      Provide everyone with the skills to be confident risk takers
The Risk Management Policy aims to anticipate, and whenever possible, avoid risks rather
than dealing with their consequences. The Risk Management Policy will be applied at both
management and operational levels, and to all operational aspects.
All personnel have a responsibility for maintaining good internal control and managing risk
in order to achieve the SPO objectives. SPO project Team members at all levels will have a
responsibility to respect applicable procedures. Non-compliance with prescribed procedures
constitutes an unacceptable risk.

 7.2.1. Effectiveness Risks Management

      The management of effectiveness risk will be ensured by three types of actions:
                 Preventive:
                           Policy analysis and dialogue to develop an adequate policy
                              framework
                           Careful analysis of relevant socio-economic environment and
                              dialogue with project‟s (objective and actions)
                           Incorporation of lessons learned in the evaluation exercise
                           Careful selection of FWC and internal working group members
                              for project document design
                           Association of final beneficiaries to design activities
                           Quality control through active participation to document
                              revisions operated by ECD
                      On-going:
                               Effective monitoring system          to   assess      performance,
                                achievements and constraints


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                     Feedback to appropriate political and senior management levels
                Ex-post:
                       Implement an efficient evaluation system to assess impact and
                        learn lessons on effective implementation of project cycle steps

7.2.2. Efficiency Risks Management
    The management of efficiency risk will be ensured with by the following actions:

                Revising every six months the PMGs in collaboration with all other
                  SPOs

                Organising an internal seminars every six months to assess efficiency
                  and revise:
                      Management structure and job descriptions of the Project Team
                      Procedures and processes
                      Reporting system
                      Plan of Actions preparation methods and format
                Black-listing FWC, contractors that have caused repeated delays

                Risk that delay in procedures deadlines:
                      Provide well in advance accurate information on deadlines and
                         promote responsible attitude
                      Enquiring reasons for delay, send warning letters or, whenever it
                         is required, revise time schedule
                Risk that external information/data are not received in due time
                      Provide well in advance accurate information on deadlines and
                        promote responsible attitude
                      Enquiring reasons for delay, send warning letters or, whenever it
                        is required, revise time schedule
                Inadequate IT development
         The IT system depends on concerned line ministry or agency. An external advisor
         will be recruited to assess the appropriateness of the existing system and
         recommend appropriate measures

7.2.3. Human Resources Risks Management
                Introduce the human resources planning

                Develop and implement HRD plan

                Develop staff performance evaluation methods

                Monitoring training results by:



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                             Asking trainees to assess training impact
                             Assessing performances improvement

 7.2.4. Partner Satisfaction Risks Management
                   Efficiently and effectively structure relationships:
                        Implement an efficient coordination system: regular meetings,
                          working groups, working groups minutes, internal reporting
                          system
                        Use regular meeting to analyse implementation performance and
                          results
                   Send warning letters in case of persistent inadequacy performance

                   Take more severe actions like: replacement of TA team members,
                        request for disciplinary actions for technical staff.


7.3 Risk Assessment by the SPO
In addition to monitoring and being active in risk management of projects, the SPO has to
ensure that the functions vested in him/her, are carried out in the way that project objectives
are met and related risks properly managed.
The identified risks have to be rated. For this purpose we shall use a two factor model, where
the factors to be assessed are:

                   Probability of the inherent risk and control risk aggregated result
                        (residual risk) will take place

                   Impact of the event if risk realises
                Table 12 - The ratings given for each factor are interpreted as follows:
                 Rating                       Probability                         Impact
                    1             Almost non-existent probability         Insignificant impact
                    2             Below average probability               Below medium impact
                    3             Average probability (50%)               Medium impact
                    4             Above average probability               Above medium impact
                    5             Definite event (has already happened)   Disaster if happens

Once each risk has got 2 ratings, these ratings are multiplied and the end results prioritised
(the highest aggregate rating being first).

The interpretation of risk assessment results based on the above gives guidance on where the
SPO should target its risk management efforts as first priority. The interpretation of the
results above is the following:




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Priority 1: Critical risks- these are the risks that got both factors rated above 3. From the
example here would appear risks 1.2. This is usually a group of risks that needs immediate
attention and detailed review of risk management activities
Priority 2: Contingent risks- these risk are to be managed before the “housekeeping risks”
as their impact may be significant, although probability of this happening is less than for
critical risks. In the example there were no such risks. Such risks are usually insured against
(e.g. a fire taking place).
Priority 3: “Housekeeping risks” –these risks have high probability of happening, but their
impact is relatively low. In the example there were no such risks. It is more a cumulative
effect that should be bourn in mind – imagine a series of small problems happening with a
large cumulative or systematic effect.
Priority 4: Minor risks – here are the risks that got both factors rated below 2. Based on the
risk tolerance level set, these risks either get attention or do not. It depends on the resources
available and on the stake-holders requirements. It has to be noted that EU and public sector
in general often operates at “zero-risk-tolerance” policy. If that is the case –also these risks
have to be carefully managed, although not as first priority


7.4 Risk Management Process of the SPO
The concepts introduced above have to become operational and assume top management
active involvement. In order to ensure clarity of responsibility the SPO or his nominee will be
appointed risk manager and take on the responsibilities of risk assessment, administration
and management.
The risk manager responsibilities will include:
                     i. Convening the initial risk assessment
                     ii. Convening the quarterly risk assessment meetings
                    iii. Identifying the key risk factors
                    iv. Receiving risk assessment statements
                     v. Preparing risk assessment statements for the CFCU
                    vi. Maintaining the risk register
                   vii. Proposing risk minimization measures
                   viii. Follow up Contractors and Final Beneficiaries to ensure that risk
                         minimization measures have been implemented


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                           ix. To organize a take part in on the spot-checks
The table below briefly describes the main activities, deadlines and responsible persons to
carry out the whole risk management.
                                         Table 13 - Whole Risk Management process
    No                       Activity                      Person responsible           Term                    Output
1          Identifying risks of the Projects               Risk Manager         Initial assessment         List of risks
                                                           Programme Managers   followed up quarterly
3.         Approving the risk lists (adding missing ones   SPO                  2 weeks after receipt of   SPO approved
           if needed)                                                           the proposals              lists
4.         Assessing the project risks                     Programme Manager    2 weeks after approval     memo of the
                                                           Risk Manager         of the risk list           meeting
5          Input of the SPO risks and assessment results   Risk Manager         In 1 week after            Database updated
           into risk management database                                        assessing NF risks
6.         Developing the risk management strategy and     SPO                   In 1 week after the       High risks of get
           measures for projects                           Risk Manager         update of database         risk management
                                                                                                           measure
7.         Introduction of new/updated controls into       SPO                  2 weeks after              Draft updated
           project management procedures /contracts etc.   Risk Manager         developing strategy        procedures/
                                                                                                           contracts etc.
                                                                                                           ready
8          Provide Risk Manager of CFCU with list of       Risk Manager         1 week after updated       Risk strategy
           risks and risk strategy                                              procedures
9          Changes planned approved by                     SPO                  1 week after receipt of    Changes
      b.                         PAO                       PAO                  drafts                     approved, updated
      c.                         SPO                                                                       practice enforced
10         Contractors and/or Final Beneficiaries          Risk Manager         2 weeks after approval
           contacted for review of their risk management                        of PAO
           procedures and measures taken
11.        Replies reviewed, site visits planned if        Risk Manager         1 month after sending      Overview of
           necessary                                                            the requests               action taken
                                                                                                           across risky
                                                                                                           projects
12.        In case of no reply, information passed to      Risk Manager         1 week after deadline      Corrective action
           PAO                                                                  of reply and no reply      requested by
                                                                                received                   PAO, problem
                                                                                                           raised to SMSC
                                                                                                           level


7.5 Sensitive Posts
A sensitive position is any post within the SPO office whose occupant could cause adverse
effect to the integrity and functioning of the institution by virtue of the nature of his/her
responsibility. The need to identify and manage sensitive posts should be part of the SPOs‟
overall objective to develop a sound management system and internal control system to
establish a list of functions where there is a risk that failure to perform them correctly for
each post could seriously harm the interests of the SPOs‟ functions. Specifically, within the
SPO offices context, establishment of a sensitive post management system protects EU/TR
financial interests against fraud and misuse and raises the awareness among the staff when
performing their mission.




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In this respect, at the level of SPO office, inventory of sensitive post and the corresponding
policy to mitigate the risk involved in the positions identifying as sensitive must be in line
with Appendix 9.




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8. Prevent, Handle and Report Irregularities and
    Frauds
8.1 Irregularity
Irregularity means any infringement of a provision of Community or Turkish law (including,
FAs, Operational Agreements) resulting from an act or omission by an economic operator
(employee, natural or legal persons or other bodies recognised by national law), which has, or
would have, the effect of prejudicing the general budget of the Communities or the state
budget of Turkey by charging an unjustified item of expenditure to the budget.

8.2 Fraud
Fraud means any intentional act or omission relating to:

                   The use or presentation of false, incorrect or incomplete statements or
                     documents, which has as effect the misappropriation or wrongful
                     retention of funds from the general budget of the European Communities
                     or from the state budget of Turkey,

                   Non-disclosure of information in violation of a specific obligation, with
                     the same effect,

                   The misapplication of funds for purposes other than those for which they
                     are originally granted.
Irregularities can occur at any stage in the life cycle of a project or programme as well as in
the day-to-day operation of any institution / organisation. Systems set up for ensuring the
detection and prevention of irregularities must therefore cover the whole project life cycle.
Although many irregularities can be detected through a desk analysis, the best way is to
implement monitoring and on the spot check and produce a written report. The SPO will
operate a system of checklists as aide memoirs to ensure that all aspects of a procedure are
checked properly.

8.3 Sources of Irregularity

 8.3.1. Irregularities that may Concern Line Ministry or Agency Staff
      Tendering phase



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                   Disclosure of information that affect the principle of open and fair
                       competition

                   Hidden a conflict of interest

                   Collusion with a tenderer
      Implementation phase: technical management
                 Inappropriate use of equipments/material supplied

 8.3.2. Irregularities that may Concern the Contractors
                   Collusion with SPO Team or Ministry/Agency staff

                   Provision of false or incorrect information in the progress reports in
                       relation to the use of inputs and to implemented activities

                   Submission of time sheets that report false or incorrect information in
                       relation to the number of working days

                   Submission of invoices that are false or incorrect

                   Submission of provisional/final acceptance of goods report false or
                       incorrect information in relation quantities and TS

 8.3.3. Irregularities that may Concern the Beneficiaries of GS
                   In addition to the above Grant Beneficiaries are particularly susceptible
                       to errors in dealing with EC Procurement procedures.

8.4 Develop Irregularities Prevention Policy

 8.4.1. Classification, Formalisation of Procedures and Information
The irregularities must be classified and the actions to be taken to prevent and react to
irregularities or to report omissions must be defined.
The SPO, as the Irregularity Officer at the SPO Office level, will inform staff and final
beneficiaries about:

                   Irregularities classification

                   Preventive actions

                   Reaction to irregularities and to omissions

 8.4.2. Preventive Actions – General Features
                   Setting clear and transparent written procedures



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                  A well-defined management system, responsibilities and management
                    procedures is formalized in the SPO management guidelines

                  Application of the “four-eyes” control principle

                  Checklists for administrative controls are included in the SPO
                    management guidelines

                  Transparent and auditable system of registration and filing of documents

                  The SPO registers and filing set up in accordance with the SPO
                    management guidelines

                  Regular reporting system on irregularities

                  Monthly reports on Irregularities are foreseen in the SPO management
                    guidelines.

 8.4.3. Preventive Actions – Specific Features

Implementation phase: Tendering process
During the tendering process, on the basis of the guidance by the CFCU, the SPO project
team will mostly rely on the strict implementation of EU tendering procedures that ensure
transparent methods for the nomination of the members of the evaluation committee.
Furthermore the SPO will propose every time different candidates without participating
directly in the evaluation committee.
Implementation phase: Administrative management

     Contractor progress reports and time sheets
                 The information contained in the contractor reports and in the time
                    sheets will be checked by a team composed of the programme manager
                    plus the concerned technical coordinators in order to ensure the access to
                    all information and a parallel double check

                  In case of doubt a meeting will be hold with the contractor team leader to
                    ask for clarification
     Contractor invoices
                 On the basis of the checklist provided by the CFCU, the contractor
                    invoices will be checked by a team composed of the programme
                    manager plus the concerned technical coordinators in order to ensure the
                    access to all information and a parallel double check



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                In case of doubts a meeting will be hold with the contractor team leader
                  to ask for clarification

                If doubts persists further enquiring will be conducted among
                  services/goods suppliers in consultation with the CFCU
Provisional/final acceptance of goods
                  A technical team will be appointed to conduct a site visit to verify
                  appropriate use of equipment/material and to check of quantities and
                  technical specification of goods. The original TS attached to the tender
                  document will be used as check list

                In issuance of the Provisional/Final acceptance, the template certificate
                  of the CFCU will be used

8.5   Reaction to Detected Irregularities
                Staff of the Line Ministry or Agency that detect suspected fraud or other
                  irregularities has to compulsory report to Irregularity Officer, SPO. The
                  staff that will omit to report proved frauds and irregularities will be
                  disciplined accordingly.

                If the Project Team member suspects that the SPO is involved in the
                  irregularity, and the irregularity is a fraud rather than a mistake, he/she
                  should report the irregularity directly to the PAO.

                The staff member who detects the irregularity is required to keep, in a
                  safe place, all original documentation (or a certified copy if the original
                  documentation must be released) proving the irregularity.

                Once reported irregularities the SPO (or the PAO) has to:
                          Investigate on the case (eventually appointing a specific
                           commission) and:

                                  In case of irregularities, that are the consequence of
                                   human errors or incompetence and that do not cause any
                                   loss, take administrative steps to prevent further
                                   occurrences




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                                         In case of the irregularities, that are the consequence of
                                          human errors or incompetence, but have financial
                                          implications, take steps to recover any loss5

                                         In case of fraud, take steps to recover any loss and take
                                          the case to the competent court

                     The documentation concerning any detected irregularity will be recorded
                        into the irregularities‟ file. The “Irregularities Files” will be available to
                        all monitoring and auditing bodies.

8.6 Reporting Irregularities

1) Immediate Report
As the Irregularity Officer, SPO should report all the irregularities detected within the SPO
office or by the SPO and reported irregularities by the line ministry immediately to the PAO
(CFCU) by using the standard form. All the documents certifying that irregularity was
committed should be annexed to the irregularity report.
2) Monthly Reports
The information and documents gathered about the irregularity after immediate report will
continue to be reported by SPO to PAO via monthly reports until the irregularity is resolved
by using the standard form. The irregularity report prepared by the Irregularity Officer in the
SPO office should be submitted to the PAO by the tenth day of the month following the end
of each month. It will be composed of three parts:

                     Irregularity detected at Ministry/Agency central level and by provincial
                        and regional grant management teams

                     Actions taken

                     Irregularity Reports prepared by provincial and regional grant
                        management teams

3) Zero Irregularity Report
If there is not a specific irregularity reported in a month, not only from the SPOs but also
from own activities and LMs activities regarding the projects in the FAs, the Zero
Irregularity Report, prepared by SPO should be submitted to the PAO by the tenth day of the

5
  Losses from staff will be recovered following the rules set up by the national legislation. Losses from
contractors and grant beneficiaries will be recovered following the rules setting up in the contract document.


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month following the end of each month by using the standard form. Irregularity Officer will
ensure that a Register of Irregularities and Irregularity File are duly established and kept.
The template of this register is attached in to this document. The Irregularity Officer should
ensure that the irregularities reported by the staff is registered to irregularity register and is
submitted to the PAO together with the measures taken by SPO.




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9. Human Resources and Ethical Behaviour
The SPO shall be responsible for ensuring that an adequate organisation, with sound internal
procedures, is established within his/her line Ministry or Agency staffed by an appropriate
number of qualified personnel to enable him/her to carry out the implementation of EU-
funded projects in a timely, effective and efficient manner.

9.1 Human Resources Requirements

 9.1.1. Skills Needed
Project coordinator: For most project implementation it is important that a single project
coordinator is nominated. This coordinator shall be available at all times as counterpart to the
Consultant. Most SPOs nominate a staff member who is intimately familiar with the project
and all of its aspects.
Technical Counterpart: In addition to the permanent coordinator it may be necessary to
identify individuals who will act as key counterpart for particular components of a project.
The number of programme technical coordinators depends on complexity of policies, IB and
training components of the programme, and on the related number of technical advisors. In
general there should be:

                    One technical coordinator each long-term TA member dealing with IB
                      concerned issues, or

                    One technical coordinator for each policy, IB or training components,
                      including several sub-components (usually the number of sub-
                      components can be estimated on the basis of working groups or similar
                      arrangements)

 9.1.2. Grant Management Teams
It is well known that the management of GSs is human resource intensive. The number of
staff needed depends of course on the type of projects involved by the grant beneficiaries. In
the case of relatively „simple‟ schemes a benchmark of about one full time staff member per
40 grant beneficiaries would be appropriate; however the ratio would fall to perhaps 1:10 for
technically complex small scale infrastructural schemes under Economic and Social Cohesion
(ESC) criteria. It may also be feasible to have a network of regionally based staff who would
undertake the time-consuming activities of visiting, advising and monitoring grant



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beneficiaries; in those circumstances the number of full time staff needed at HR would be
much less and would depend on the spilt of responsibilities.

9.2 Conduct Training Needs Analysis
The training needs analysis (TNA) will be conducted every years in collaboration with EUSG
which is the main DIS training coordinator. A TNA team will be set. It will be composed of
the programme manager, experienced staff from EUSG, experienced staff from Personnel
Department, and staff from other well established line ministries or agencies.
To implement the training needs analysis the team will:

                  Take stock of job descriptions

                  Analyse staff performance assessment reports

                  Training assessment reports

                  Analyse quality of outputs (project documentation, minute, reports etc.)

                  Analyse efficiency and effectiveness of management procedures and
                    reporting system

                  Interview CFCU staff to have feedback on SPO Project Team
                    performance

                  Interview ECD staff to have feedback on SPO Project Team
                    performance

                  Interview IET staff to have feedback on SPO Project Team performance

                  Interview each SPO Project Team staff member including Grant
                    Management Team members at any levels to assess their skills in
                    relation to needs
A TNA report will be prepared and its conclusion will be discussed with the SPO Project
Team.

9.3 Ethics Policy
Ethics are the standards of conduct that indicate how people are expected to conduct
themselves. The purpose of ethical principles and standards is to avoid situations where a
member of staff might be unfairly accused of having some potentially conflicting interest in
anything he/she may be involved in through their work with the SPO Project Team. The




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                          Programme Implementation Manual (PIM)


following shall apply to all members of SPO Project Team during their activities linked to the
implementation of EC-funded projects regardless of rank position and regime.
The employee shall sign the following Declaration of Confidentiality and Impartiality:

 9.3.1. Principles of Ethical Conduct
SPO Project Team member shall:

                  Not hold financial interests that are in conflict with the conscientious
                    performance of their official duties and responsibilities

                  Not engage in any financial transaction in order to further any private
                    interest using non-public information which they obtain in the course of
                    their employment

                  Put forth honest effort in the performance of their duties

                  Make no unauthorised commitments or promises of any kind

                  Not use their public offices for private gain

                  Not place themselves under any financial or other obligation to outside
                    individuals or private/public organisations which might influence them
                    in the performance of their official duties

                  Act impartially and not give preferential treatment to any private or
                    public organisation or individual

                  Protect and conserve public property and shall not use it for other than
                    authorised activities

                  Not engage in outside employment or activities, including seeking or
                    negotiating for employment, that conflict with official duties and
                    responsibilities

                  Promptly disclose waste, fraud, abuse, and corruption

                  Adhere to all laws, regulations, and policies that are applicable, and
                    provisions of the Turkish Civil Servants Law (no: 657) with particular
                    reference to its articles 6-16 (duties and responsibilities); prohibition of
                    commercial activities (art. 28); prohibition of receiving any benefit or
                    gift (art. 29-30); prohibition of confidential information disclosure (art.
                    31)




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                  Endeavour to avoid any actions that would create the appearance that
                    they are violating the law or the ethical standards of the CFCU.

                  Be exposed, in the event of any breach of these rules, to disciplinary
                    action as specified both in employment contracts and in the law n° 657.

 9.3.2. Standards
SPO Project Team member are expected to strive to highest possible standard of service.
They shall be expected, through agreed procedures and without fear of recrimination, to bring
to the attention of the appropriate level of management any deficiency in the provision of
service. They must report any impropriety or breach of procedure. This would be to the SPO.

 9.3.3. Abuse of Official Capacity
SPO Project Team member shall not act with the intent to obtain a benefit or with intent to
harm or defraud another, to intentionally or knowingly misuse any thing of value belonging
to the government or the EC that comes into their custody or possession by virtue of their
office or employment.

 9.3.4. Abuse of Official Information
All work of the SPO Project Team is confidential and must not be discussed outside the
office. Particular attention must be paid to requests for statements to the press and other
media. Only the SPO may make any sort of statement to the media, if he/she has consent of
line minister. If information is given, although it may be factually correct, it may well be
open to misinterpretation in the form in which it is published or broadcast. SPO Project Team
member shall not:

                  In reliance on information to which he/she has access in his/her official
                    capacity and which has not been made public

                  Acquire or aid another to acquire a pecuniary interest in any property,
                    transaction, or enterprise that may be affected by the SPO

                  Speculate or aid another to speculate on the basis of the information

                  Disclose or use, with the intent to obtain a benefit or with intent to harm
                    or defraud another, information for a nongovernmental purpose that he
                    or she has access to by means of his or her employment and that has not
                    been made public.




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Information concerning a member of staff's private affairs must not be supplied to any person
unless the consent of that member of staff is first obtained.

 9.3.5. Benefits, Gifts, Honoraria and Travels, Conference Attendance
A "benefit" is anything reasonably regarded as pecuniary gain or pecuniary advantage,
including benefit to any other person in whose welfare an employee has a direct and
substantial interest.
No SPO Project Team member may solicit, offer, confer, agree to confer, accept or agree to
accept any benefit in exchange for his or her decision, opinion, recommendation, vote, or
other exercise of official power or discretion.
SPO Project Team member who exercise discretion in connection with contracts, purchases,
payments, claims, and other pecuniary transactions may not solicit, accept, or agree to accept
any benefit from any person the employee knows is interested in or is likely to become
interested in any contract, purchase, payment, claim, or transaction involving the employee's
discretion.
SPO Project Team members shall disclose to their respective hierarchy any benefit received
in the course of official business.
SPO Project Team members may accept plaques and similar recognition awards, including
achievement and recognition awards from the SPO Project Team.
SPO Project Team members may not solicit, accept, or agree to accept an honorarium in
consideration for services they would not have been asked to provide but for their official
position or duties. This prohibition includes a request for or acceptance of a payment made to
a third party if made in exchange for such services.
SPO Project Team members may accept the direct provision of or reimbursement for
expenses for transportation and lodging incurred in connection with a speaking engagement
at a conference or similar event. Meals provided as a part of the event or reimbursement for
actual expenses for meals may also be accepted.
To qualify for travel reimbursements (including aircraft), the purpose of a trip must be "state
business" or "official business" of the SPO Project Team.
SPO Project Team members should be aware that it is a serious criminal offence corruptly to
receive or give any gift, loan, fee, reward or advantage for doing, or not doing, anything or
showing favour, or disfavour, to any person in their official capacity. If an allegation is made
it is for her/him to demonstrate that any such rewards have not been corruptly obtained.


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                         Programme Implementation Manual (PIM)


All attendances at conferences or other seminars, trainings or similar gatherings should be
approved by the SPO and be demonstrably beneficial to the SPO Project Team or to staff‟s
training and development or profession.




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