Additional Financing -- Jordan Education Reform Support Program-for-Results Fiduciary Systems Assessment Addendum 1. The envisaged Additional Financing (AF) will continue using the same fiduciary systems of the ongoing PforR (Jordan Education Reform Support Program-for-Results). The original Fiduciary Systems Assessment (FSA), conducted in 2017, was updated for the ongoing PforR operation for the purpose of this envisaged additional financing. The update was done remotely due to the current lock-down in Jordan due to the COVID-19 pandemic but is based on the implementation findings of the ongoing operation. 2. The findings of the updated FSA assessment concluded that the overall fiduciary and governance framework provides a reasonable assurance that the Program funds will be used for the intended purposes of the proposed AF. Fiduciary Risks 3. Fiduciary risk continues to be rated as "moderate". The updated FSA continues to consider that the Program systems provide reasonable assurance that the financing proceeds will be used for the intended purposes, with due attention to the principles of economy, efficiency, effectiveness, transparency, and accountability. The following remain the main identified risks: (i) possibility of lack of financial sustainability and funding predictability due to possible budget cuts caused by the fiscal stress Jordan has been facing in recent years and significantly increased due to the COVID-19 pandemic. Based on the 2020 budget law, the Program is still aligned with the expenditure framework. The original PforR was valued at US$700.0 million, representing 10 percent of the US$7 billion Education Strategic Plan (ESP, the Government program), and including key activities that focus on access for early childhood education (ECE) and quality for ECE, basic, and secondary education. The proposed AF will operate within the original boundary of the Government program. The PforR Program boundary will expand by US$222 million in terms of the expenditure framework, of which $100m is being provided through the AF. The Ministry of Finance (MOF) has been providing the Ministry of Education (MOE) with the quarterly allocations without any significant delays or reductions until the pandemic lockdown was applied mid-March, 2020, where transfers are only enough to cover salaries. However, recently, MOF resumed providing monthly allocations for both recurrent and capital; (ii) further delays in implementation of e-procurement may impact the standardization and efficient implementation of procurement activities and will exacerbate the already existing cumbersome administrative processing; iii) weak capacity for contract management; and iv) non-systematic coordination and integration of procurement of works above the MOE threshold of 1 million JOD and that is implemented centrally by the Ministry of Public Works and Housing (MOPWH). The coordination is needed to allow MOE to monitor the works progress and thus launch procurement of equipment and furniture in a timely manner to be delivered at school when works are completed. 1 4. Risk mitigation is expected as follows: (i) on an annual basis, the MOE budget will be monitored and compared to program expenditure framework to identify any significant variation that would hinder the achievement of project developmental objectives; (ii) procurement: (1) timely deployment of the Jordan National E-Procurement System (JONEPS) that will streamline procurement processing and contract management; (2) TA activity towards defining standards for Data Architecture in order to allow systems to communicate with JONEPS for planning aspects and inventory; and (3) systematic coordination and updates on procurement processing and contract management and forecasting with MOPWH that is under the scope of the USAID program, Enhancing School Management and Planning Project (ESMP). Original Program performance and required actions implementation 5. The original Program could not achieve the expected efficiency in procurement due to the delays of the Government in deployment of JONEPS. The World Bank extended funding to the Ministry of Planning and International Cooperation (MOPIC) and MOF/ General Procurement Department towards strengthening reform management (P172421) and enhancement of JONEPS implementation (P171965), respectively. Funds were mobilized in December 2019 and are under implementation. The first instrument will be supporting training and operationalization of the units of procurement policy and complaints, while the second will support deployment of JONEPS, starting with MOE as a pilot. The enhancement of the public procurement system will take effect in MOE by mid-2021. Monitoring of procurement data and efficiency indicators will be made easier through the system, but meanwhile, spreadsheets will be used for that purpose. 6. The overall expenditures of the Program are still aligned with the expenditure framework. The original PforR was valued at US$700.0 million, representing 10 percent of the US$7 billion ESP (Government program), and including key activities that focus on access for ECE and quality for ECE, basic, and secondary education. The proposed AF will operate within the original boundary of the Government program. The PforR Program boundary will expand by US$222 million in terms of the expenditure framework, of which $100m is being provided through the AF. 7. Similar to the ongoing PforR operation, MOE shall execute the AF activities in accordance with the World Bank's Guidelines on Preventing and Combating Fraud and Corruption in Program-for-Results Financing. The implementation agencies will (i) share information with the World Bank regarding all allegations of fraud and corruption in connection with the Program, investigate all credible allegations received, report to the World Bank on actions taken, and cooperate in any inquiry that may be conducted by the World Bank into allegations or other indications of fraud and corruption in connection with the Program; and (ii) monitor and abide by the World Bank's list of debarred/suspended firms. Background and Institutional Arrangements Institutional Framework 8. Ministry of Education: The first Ministry of Education bylaw was issued in 1939. The Ministry is responsible for the educational system pursuant to the provisions of Education Law No. (3) for the year 1994, which includes complete details related to the philosophy of education, its goals and the educational policy principles as well as the Ministry's work, tasks, staff, educational stages, the tasks of 2 the Education Council, the principles of curricula and textbooks, general examinations and private and foreign educational institutions. 9. The expenditures to be incurred under the Program will continue to form part of the national budget systems of the Government ministries. The Program will be subject to the Government’s public financial management (PFM) arrangements, which have been assessed through various analytical pieces.1 A summary of applicable PFM systems, rules, procedures, and oversight mechanisms is described in the following paragraphs. Legal Framework 10. No changes are foreseen in the legal framework for the AF -- the below laws continue to apply: (a) The Organic Budget Law (2008) presents the tasks and responsibilities for the MOF General Budget Department (GBD), as well as a few issues on the budget preparation process. Important aspects on budget execution are only regulated by the General Budget Law and the Budget Law for the Government Units approved for each fiscal year. The Government is revising the current version of the law, with the revised legislation expected to be submitted to the Parliament by end of 2017. (b) The Financial By-law (1994) and its Amendment (2015). The basic principles related to revenues, expenditures and advances, cash and debt management, financial accounting basis and records, and financial control are outlined in this regulation and in the Instructions for Application of Financial Affairs (1995). (c) The Financial Control By-law (2011) and its Amendment (2015) present the internal controls framework and illustrate the related financial revenue and expenditures ex ante review/approval procedures, roles and responsibilities, and positions of the MOF to centrally manage and overlook the financial control functions established in line ministries and governmental units. Considered a milestone, the revised by-law (2015) clearly distinguishes between the internal control and internal audit functions, which are commonly mixed in the public sector. (d) The Audit Bureau (AB) Laws of 1952 and 2007. The Jordan AB is governed by the underlying laws of 1952 and later amendments, the latest in 2007. The laws do not provide the necessary financial and administrative independence for the AB, prerequisite immunity, and security of tenure of its president, and still focus on ex-ante control. A recent amendment to the Audit Bureau Law was drafted and approved by the Cabinet in 2013 but has not been endorsed by the Jordanian Parliament to become effective. The proposed amendments will further strengthen the independence of the AB by bringing it closer to international practices and standards promulgated by the International Organization of Supreme Audit Institutions. (e) Anticorruption legislation. The Jordan Integrity and Anti-Corruption Commission (JIACC) is established under the Amended Anticorruption Commission Law, most recently amended in 2014 to include protection of “…informers, witnesses, informants, and experts in corruption cases and their relatives and closely related persons.� 1 Recent assessments include the 2016 Public Expenditure and Financial Accountability Assessment. 3 (f) Public Procurement. A new by-law No. 28/2019 was ratified in May 2019 and made effective in November 2019. The by-law foresees establishment of two independent units, one to regulate the sector and advise on policies and another one to handle procurement complaints when not resolved by the implementing agency and enforces usage of e-procurement. The governmental agencies (ministries, public institutions, bodies, and departments mentioned in the General Budget Law and the Budget Law for Government Units) are implementing the new government procurement By-Law that has been assessed to be satisfying international practices and abiding by procurement principles of transparency, fairness, economy, and value-for money. The reform is still ongoing, and deployment of e-procurement at the level of Ministries is planned by end- 2020. Updated Assessment of Fiduciary Systems Budget Preparation and Execution 11. The updated assessment confirms that Jordan’s budget systems are adequate for the PforR AF. Budget preparation continues to be prepared without any significant delays and budget draft and final are published on the GBD website. Budget preparation and execution continue to be governed by the Organic Budget Law No. 58 of 2008, which sets out the responsibilities of the GBD, a separate unit which reports directly to the Minister of Finance, but the core principles relating to revenue and expenditure management and accounting, and financial control, are specified in the Financial By-law No.3 (1994) as subsequently amended, and in the Application Instructions for Financial Affairs No. 1 (1995). Rules limiting the extent to which budgetary provision can be reallocated during the year are set out in each year’s General Budget Law. A more comprehensive Organic Budget law has been under discussion for several years, but no proposals have been submitted to the National Assembly. 12. The Government continues to use systems for budget classification and chart of accounts that conform to international standards and deploys a basic but effective results-oriented budgeting framework, all of which provide the means to track government spending. Jordan has a robust classification system, which includes the most important classifications and is broadly consistent with the IMF’s Government Finance Statistics Manual 2001, including administrative, economic, functional, geographical, and program classifications. These classifications are included in the current chart of accounts allowing for all transactions to be reported in accordance with the appropriate standards. The Government Financial Management Information System (GFMIS) is used for budget preparation. 13. The budget is published on the GBD website, while final accounts and the monthly General Government Finance Bulletin (includes budgetary Government finance statistics aggregated according to the economic and functional classifications) are published on the GBD website (http://www.gbd.gov.jo). 14. GFMIS functionalities do not as yet fully meet the requirements of all budget actors during the budget preparation and execution. The GFMIS offers limited functionalities for: (a) presentation of an initial policy-focused budget submission; (b) entering of multiple quarter and multiyear commitments; and (c) capturing and populating the outstanding commitments and outstanding invoices for arrear 4 monitoring. As a result, arrears have continued to be a problem. The Government has not been fully benefiting from the GFMIS to monitor the problem. Mechanisms designed to facilitate regular monitoring of arrears have recently been established at the MoF where a small team under the cash management division is assigned to track and monitor arrears. Public Procurement 15. Major reforms are ongoing. A new by-law No. 28/2019 was ratified in May 2019 and made effective in November 2019. The by-law foresees establishment of two independent units, one to regulate the sector and advise on policies and another one to handle procurement complaints when not resolved by the implementing agency and enforces use of e-procurement. The governmental agencies (ministries, public institutions, bodies, and departments mentioned in the General Budget Law and the Budget Law for Government Units) are implementing the new government procurement By-Law that has been assessed to be satisfying international practices and abiding by procurement principles of transparency, fairness, economy, and value-for money. The reform is still ongoing, and deployment of e- procurement at the level of ministries is planned by end-2020. A procurement Special Tender Committee at MOE may need to be established for the Program, should MOE need to process activities above the below thresholds established under article 76, and 81 of the Government Procurement By-Law no. 28 for 2019. Else, those activities shall be processed centrally by the MOF /General Procurement Department (for goods and consulting services) or by MOPWH (for works and consulting services related to works). Budget Performance Analysis 16. Budget expenditures outturn analysis for MOE for the year 20182 shows variations (budget vs actual) as demonstrated in Table 1. The average variance is 6 percent which shows the fiscal stress that Jordan is under during the last couple of years, causing budgets cuts mainly in capital expenditures. The overall expenditures of the Program are still aligned with the expenditure framework. Treasury Management and Funds Flow 17. AF will follow Jordan treasury management where all Government Units including the MOE are required in accordance with the Surplus Laws (2007 and 2015) to keep their bank balances in the Treasury Single Account (TSA), and to surrender any surpluses to MoF. In Jordan, the Public Treasury Directorate (PTD) of the MOF is responsible for managing the TSA through which all Ministries channel all their expenditures and revenues. The Central Bank of Jordan (CBJ) maintains all Treasury accounts, to which the MOF has real-time access. For all line ministries, the CBJ maintains expenditure and revenue sub- 2 Project implementation started in 2018 and final accounts of 2019 are not yet published. 5 accounts, the balances on which are swept on a daily basis so that each sub-account has a balance of zero at the end of the day. A daily report by the CBJ allows the Treasury to know the source of all financial transactions. The funds of the World Bank will be transferred to the Treasury current account at the CBJ. MOE is responsible of submitting withdrawal applications with the necessary supporting documents evidencing DLIs achievements. Table 1: Ministry of Education budgeted and actual spending, 2018 Budget 2018 Actual 2018 JOD JOD Kindergarten Current expenditure 2,985,000 2,875,758 Capital expenditure 1,436,000 1,144,498 Total 4,421,000 4,020,256 9% Basic Education Current expenditure 674,233,500 666,307,839 Capital expenditure 51,756,650 50,842,974 Total 725,990,150 717,150,813 1% Secondary Education Current expenditure 94,178,000 93,030,641 Capital expenditure 16,370,350 9,274,114 Total 110,548,350 102,304,755 7% Admin&Supportive services Current expenditure 52,109,000 50,874,457 Capital expenditure 2,805,000 1,510,457 Total 54,914,000 52,384,914 5% Average change 6% 18. MOF has been providing MOE with the quarterly allocations without any significant delays or reductions until the pandemic lockdown was applied mid-March 2020, where transfers are only enough to cover salaries. However, MOF starting early May 2020 resumed providing monthly allocations covering both recurrent and capital. Accounting and Financial Reporting 19. The updated assessment concludes that the accounting and financial reporting systems are found acceptable for purposes of the Program. The Government adopts the cash basis of accounting. The Government adopts a chart of accounts that is compatible with the Government Finance Statistics Manual 2001. 20. The GFMIS has facilitated the preparation of budget execution reports to GBD, on a monthly basis, and are sent to the GBD. These reports are generated through GFMIS and conform to classification in the 6 Court of Account (COA), allowing for the comparison of actual performance to budget. There is a two-way flow of information between MOF and MOE. Spending of approved recurrent budgets can only take place after receipt by the ministries of a Public Financial Order issued by MOF. Similarly, a Special Financial Order is required for the spending of capital expenditures. The monthly General Government Finance Bulletin includes budgetary government finance statistics aggregated according to the economic and functional classifications (budget versus actual). The monthly financial positions sent by line ministries to the GBD/MOF present data in administrative, economic, program, funding, and geographical classifications. 21. Finalization of the annual accounts is required by law by June of the following year, and this has been complied with during the recent years. The final accounts are published on the MOF website. The annual financial statements are prepared by the Directorate of Accounts of MOF and submitted to the Audit Bureau usually in June of the following year. The financial statements are audited by the Audit Bureau on receipt and a report of the findings is sent to Parliament. The final accounts are published on the MOF website. According to IMF’s Middle East Regional Technical Assistance Center (METAC, 2016), the financial statements are not prepared according to the International Public Sector Accounting Standards (IPSAS). Rather, they are prepared on a modified cash basis of accounting and do not yet meet IPSAS standards. MOF has plans to conform to IPSAS standards with technical assistance from development partners. 22. The current GFMIS implementation utilizes a subset of the functionalities of the underlying application software. The current core application software comprises: (a) Hyperion for budget preparation; (b) Oracle Financials for budget execution; and (c) software for interfacing to other software for debt management, payroll, bank reconciliation, and revenue management. The GFMIS is fully utilized for budget execution; yet, for budget preparation, there are manual interventions with various ICT tools being used. However, the GFMIS functionalities do not as yet fully meet the requirements of all budget actors during the budget preparation and execution. The GFMIS offers limited functionalities for: (a) presentation of an initial policy-focused budget submission; (b) entering of multiple quarter and multiyear commitments; and (c) capturing and populating the outstanding commitments and outstanding invoices for arrear monitoring. As a result, arrears have continued to be a problem. The Government has not been fully benefiting from the GFMIS to monitor the problem. Mechanisms designed to facilitate regular monitoring of arrears have recently been established at the MoF where a small team under the cash management division is assigned to track and monitor arrears. Internal Controls and Internal Audit 23. Based on the updated assessment, the overall control environment continues to be acceptable for purpose of Program implementation. Budget execution controls are implemented and applied consistently throughout the ministries in accordance with the applicable Financial By-law (1994) and its Amendment (2015) and the Financial Control By-law (2011) and its Amendment (2015). The MOF regularly issues instructions detailing acceptable procedures to be followed by all ministries including MOE. The budget execution systems at MOE implement prescribed controls, which include: (a) technical approval by the beneficiary department; (b) finance staff checking and approval; (c) periodic, ad hoc reviews by resident internal auditors; and (d) exercise of an expenditure controlling function by the MOF’s financial 7 controllers assigned to respective spending units. 24. The MOF-assigned financial controllers oversee transaction-based compliance controls over payments, recording of transactions, and production of periodic and final accounts by responsible entities. In practice, no payments can be authorized and processed before financial controllers verify and sign off on payment vouchers. In addition to resident MOF financial controllers, MOE have internal auditors who mainly perform the job of internal/financial controllers. Internal audit activities are primarily confined to ex ante review of receipts, expenditure vouchers, and disbursements. Internal audit activities are, in this case, not designed to comply with practices and standards promulgated by international standard setters. Ultimately, there appear to be excessive ex ante controls by the MOF financial controllers and internal auditors. 25. The absence of an effective ex post audit in accordance with recognized international standards weakens the effectiveness of the internal audit function and its suitability to effectively support program implementation. To mitigate risks presented by this deficiency, this assessment recommends extending the scope of work proposed to be done by the external auditor to include a review and assessment of the effectiveness of the internal control environment in beneficiary entities. The annual budget laws prohibit overcommitments or reallocations between budget lines. Financial controllers play a key role in making sure payments are within approved budget allocations. Payroll 26. The updated assessment confirms that an effective functional payroll management system is in place. Payroll is centralized at MOE headquarters, administrated by the payroll department at the Directorate of Employee Affairs (HR). The payroll systems in place have a good degree of integration and reconciliation between the position controls, personnel records, and payroll registers. The payroll system in Jordan follows the Civil Service Bureau instructions and is in line with the national financial law and internal controls regulation, in addition to instructions issued by the MOF. HR is responsible for receiving the information for the appointed employee for entry into the automated HR database system. The HR department ensures the completeness of information and the data entry of related salary entitlements through an automated system and record archival both in the system and in paper files. HR input in the system is subject to both automated and human checks. A payroll schedule is prepared on a monthly basis and subject to several layers of approvals (payroll officer, head of payroll unit, the department manager [budget holder], Internal Control Department, MOF financial controller, and the financial management manager). Salaries are transferred to employees’ and teachers’ personal bank accounts. Monthly reconciliations are prepared in the system and shared with the internal control unit and MOF representative. At headquarters, daily time attendance sheets based on an automated attendance register are maintained by the attendance supervisor, who reports absences to the HR and responsible departments. Supervisors confirmed that they strictly ensure all employees are in place and functional. For teachers, monitoring of teachers’ attendance and salary sheets is within the capacity of the school principal. All payroll records are kept in a secure, centralized computerized payroll database that is updated daily from paper-based reports from the various directorates. The database is audited by an internal audit mission within HR to ensure that all changes are supported by appropriate documentation. Additionally, there is a regular validation of the number of staff under the responsibility of each 8 directorate and district by site visits by the MOE internal audit unit that also checks the data quality. The Audit Bureau of Jordan also audits the data. Procurement Profile 27. This assessment confirms that existing procurement arrangements are adequate to support the procurement activities envisaged under the AF. No exclusion of contracts will be observed since all individual contracts under this Program are deemed to be estimated below the following threshold values: (i) works (including turnkey, supply & installation of plant and equipment, and PPP) US$115,000,000 equivalent; (ii) goods and non-consulting services US$75,000,000 equivalent; and (iii) consulting services US$30,000,000 equivalent. The procurable expenditures under the Program are expected to remain as per original Program and mainly related to consultant services, works, furniture, and equipment related to Kindergarten classrooms (extensions and rehabilitations). However, to compensate for the school closures from the COVID-19 lockdown, the MOE is exploring digital activities related to distance learning and teaching. Accountability 28. In relation to strengthening accountability of use of public funds, the Jordan Audit Bureau has fully withdrawn from conducting ex-ante auditing in all line ministries starting 2019 in compliance with INTOSAI standards (except the Ministry of Agriculture). This has provided the Bureau with operational independence from the auditee as well as allowing the Bureau to focus on financial and performance audits. Additional progress is witnessed by the establishment of a special committee to review and solve the main audit issues raised in the audit reports during the past years including the most recent audit report of 2018. This shows the Government’s seriousness in following up and addressing the audit concerns reported by the Audit Bureau in the annual audit reports. The first audit report of the PforR covering the period from inception until December 31, 2018, was submitted on time. The auditor issued a clean opinion on MOE financial statements and the management letter did not report any significant weaknesses in internal controls. The next audit report for the year ended December 31, 2019, is due for submission no later than June 30, 2020. Program Arrangements for Managing Fraud and Corruption Risks 29. As part of the FSA, the degree to which the Program systems handle the risk of fraud and corruption, including complaint mechanisms, was assessed. The Program embeds several fraud and corruption prevention, deterrence, and detection mechanisms in existing arrangements, including: (a) publication of Program information by MOE, including provision for handling stakeholder complaints; (b) comprehensive and clearly articulated procedures governing the use and accountability of funds, reflected in the PFM legislation, regulations, and operational guidelines; 9 (c) a strong internal control and compliance monitoring mechanism, including: (i) internal control and internal audit; (ii) periodic program progress monitoring by the DCU; (iii) strong compliance monitoring by the MOF financial controllers and internal auditors; and (iv) effective auditing arrangements including an extended scope of audit focusing on systems strengthening applying a risk-based approach; (d) a strong track record of timely responsiveness in addressing and resolving audit findings; and (e) effective arrangements for segregation of accountability and reporting functions. 30. These mechanisms will be complemented by proposed PAP remedies that address identified gaps and strengthen overall governance and risk management arrangements. Application of the Anticorruption Guidelines 31. The World Bank’s Anticorruption Guidelines will be applicable to the Program as a whole. Specific requirements of the World Bank’s Guidelines on Preventing and Combating Fraud and Corruption in Program-for-Results Financing are the following: (a) Sharing information regarding all allegations of fraud and corruption in connection with the Program, investigating all credible allegations received; reporting to the World Bank on actions taken, and cooperating in any inquiry that may be conducted by the World Bank into allegations or other indications of fraud and corruption in connection with the Program. (b) Procurement entities monitoring and abiding by the World Bank’s list of debarred/suspended firms. It will be the responsibility of the internal audit to monitor compliance of the different entities with this provision in terms of verifying contractors’ name against the World Bank debarred/suspended list. 32. The Jordanian Anticorruption Commission (JACC), established in 2005, has over the years established elaborate arrangements to prevent, deter, and investigate fraud and corruption. It is headed by a board comprising a chair and five members—eminent persons nominated for a limited two-year period. The JACC has departments responsible for public outreach and awareness; information management and investigation; and quality assurance. It closely collaborates with various stakeholders responsible for fiduciary oversight and the Judiciary. The JACC continues to receive capacity building support, including ongoing twinning arrangements with the Finnish anticorruption agency and recent technical assistance from the World Bank Group for establishment of a comprehensive database. 33. Jordan ranks fifth among Arab states on the 2019 Corruption Perception Index (CPI), coming after the United Arab Emirates, Qatar, the Kingdom of Saudi Arabia, and Oman. Jordan scored 48 points out of 100 on the 2019 index, down by one point compared with the 2018 score. This slight drop is due to a mild drop in six out of eight sources used to measure the overall average, namely in relation to weak governance and bribery prevention. This clearly illustrates the referred to weakness, especially in relation to increased “wasta� (or nepotism) to obtain services from certain institutions. 10 34. The Government launched several initiatives to strengthening the rule of law3, protecting public money4, and combating corruption5 that are profound steps in the correct direction yet there is need for a holistic approach to enhance integrity and transparency in anti-corruption measures: (a) publishing periodic and updated public reports on the government’s fulfillment of its commitments to fight corruption; (b) enforcing control and oversight over political money and funding; (c) exercising preemptive and periodic disclosure of cases that are referred to the competent courts with respect to corruption and misuse of public office by the relevant authorities; (d) publicizing financial disclosures and beneficial ownership, as well as limit conflict of interest; (e) disclosing the number of objections filed against tenders, as well as the measures taken to address those objections, and in the event the objections are justified, it is necessary to clarify the corrective measures that are taken; (f) advancing the implementation of digitalization of public services; (g) promoting e a deep understanding on the concepts of integrity, transparency and accountability in order to combat corruption among school and university students through a specialized scientific curriculum; and (h) simplifying investment procedures through downsizing bureaucratic red tape that foreign and local investors have to deal with. Transparency 35. Key institutions involved in public financial accountability have established elaborate public information sharing arrangements on their websites. (a) The MoF publishes multi-year budget planning and execution reports, including key performance indicators covering all core ministries and departments. These were observed to be comprehensive and maintained up to date. (b) The Jordan Audit Bureau publishes its annual report covering the outcome of audits of all ministries including MOE subject to its audit. (c) The JACC has established a comprehensive mechanism for receiving, investigating, and reporting on all allegations received from the public. (d) Procurement notices and contract awards are required to be published as the Procurement by- law 28 (2019) article no. (6) using traditional and/or electronic means. (e) Public procurement complaint mechanism is established by the Public Procurement By-Law no. 28 for 2019 and further detailed in consequent implementation instructions. The committee is housed at the Prime Ministry and is expected to be operational by end 2020. (f) JONEPS deployment will increase transparency of procurement processing and contract management and will allow building a reliable database on the system performance, among others. 36. Access to information. There were no consequences for government departments, if they failed to fulfill their obligations as stated in the law. Furthermore, the petitioner is required to cover the 3 Several laws were amended, including the Illegitimate Profit Law, the Audit Bureau Law, and the Integrity and Anti-Corruption Law. 4 A new approach was adopted in screening the queries and violations listed in the Audit Bureau’s report and established joint committees to follow up on recommendations and rectify the situation, in addition to referring the necessary cases to the Integrity and Anti-Corruption Commission. The Unified Procurement Bylaw (the government’s Procurement Bylaw number 28 for 2019) served to establish a unified competent authority concerned with government tenders and procurement. 5 The Council of Ministers has approved the Recruitment Bylaw for leadership positions number 78 for 2019, which provided some procedures that enhance the principles of transparency, as well as the policy of open data and cloud computing. 11 expenses associated with the production of information with no specific ceiling. 37. Public complaints handling. A Central Government Complaints Management System is maintained in the Ministry Of State of Institutional Performance Development (MOSIPD) as a central entity for receiving and monitoring resolution of citizens’ complaints directly with all concerned government agencies. The management and maintenance of the system is supervised by the Government Complaints Management Unit at the MOSIPD’s Government Services Improvement Directorate. The unit receives citizens’ complaints on services provided by government departments, corporations, and municipalities and follows up with the National Contact Center. The system generates monthly reports that provide a basis for setting performance indicators and making appropriate decisions to reduce citizens’ complaints and address negative trends in a practical and evidence-based approach, in line with the vision of His Majesty King Abdullah II for better government services achieved by listening to citizens, taking their suggestions into account, and considering them as key partners in developing government services. The Central Government Complaints Management System serves as a central outlet that guarantees the confidentiality of complaints and ensures that they are handled in a professional and transparent manner upon verification of the complainant’s identity through databases linked to the system. 38. Code of ethics for public servants. All state bodies, including MOE, follow the code of ethics for public servants. In general, the code of ethics sets rules of behavior for employees and aims to strengthen public confidence in the professionalism and conduct of employees. The code defines relationships with citizens, professional behavior, conflicts of interest, relations with colleagues, personal behavior, and so on. 39. Asset disclosure. The Financial Disclosure Department by-law increased the number of individuals from the public and private sectors who are required to submit financial disclosures. Nevertheless, the law is not as effective as an investigation tool because assets disclosed by public officials in financial statements are not verified by the Financial Disclosure Department unless there is a complaint against the public official. 40. Conflict of interest. In addition, bidding documents for public procurement contain ethics clauses, which regulate interactions between the employer and the bidders with regard to the process of bid examination, clarification, and evaluation; conflict of interest; unlawful agreement with competitors or influence on the evaluation committee; and so on. Also, the requirement of this part of the bidding document is that the contractors shall act professionally, impartially, and in accordance with the code of ethics of their profession. 12