Researcher4689: The disposal process is made public by open tenders where everyone can participate. Peer Reviewer two states (see below) 'the process of disposing of public assets is managed by the Public Procurement and Property Disposal Service (PPPDS), established in 2010 under the Ministry of Finance. Tenders are advertised on the organisation's website ( http://www.pppds.gov.et/).' Tenders are also published in newspapers (such as the Addis Zemen and 2Maerkato, cited above) but no information is made available on how they are handled, what their proceeds are, or how they are spent.

As seen in the Merga Sori article, the lack of transparency regarding the proceeds from these tenders have led to speculation from civil society about corruption in these processes.

Response to peer reviewer 1: disagree. There are procedures and controls over asset disposals and these are public. Score maintained.

Researcher4689: The Federal General Auditor is tasked with auditing the assets and any income of all ministries and agencies of the Federal Government. Any problems identified by the Auditor is then sent to the Ministry of Justice and the Federal Anti-Corruption Commission. The results of these audits are selectively publicised by the agencies and the public does not have access to all of the relevant documents.

To date, no cases of corruption in asset disposal have been publicised. The independence of the FGA and the FEACC is questionable, however, as, were a case to be publicised in the future, it would be with the approval of the defence Ministry rather than due to independent oversight provided by these auditing bodies. Ultimately, the powers of the FGA and the FEACC to oversee asset disposal processes (like all other activities) is limited only to what the MoD defines as their remit, and the MoD have the final say in these matters.

Researcher4689: The published defence budget is not divided up according to the categories of secret/non-secret, but rather through the divisions between the army and the administrative MoD. SIPRI points out that: 'it is rarely possible to find data for off-budget sources of spending, as these are by their nature not the subject of public accountability and reporting. The problem of untraceable extra- or off-budgetary spending is particularly severe in many countries in Africa and the Middle East, as well as some countries in Asia.’

Given that in Ethiopia, the defence sector has the authority to not disclose information on the grounds of national security (see Q29 for more details), there is little transparency surrounding the secret budget.

Researcher4689: Information deemed sensitive to national security - by implication, everything that could be categorized as secret - can by law be withheld by defence institutions. Defence spending is presented to the Foreign, Defence and Intelligence committee using aggregated terms and it is impossible to tell what went to secret and non-secret activities.

The legal framework for this can be found in proclamation 55 (1) no. 72 (3), which reads as following: 'Notwithstanding the provision of sub article (3) of article 70 of this proclamation and sub article (2) of this article, top secrets designated by the minister, for the purpose of defending national interest and secrets regarding manpower profile, book of accounts and payment documents shall not be disclosed to anybody.'

Researcher4689: According to Interviewee 1, all security sector agencies and ministries have to submit reports annually to a parliamentary committee, the results of which are often debated in parliament. But the budgets of the military and intelligence often lack detail and are aggregated numbers for various departments and divisions rather than a detailed break-down of the budget according to activities.

Furthermore, the fact that the Ministry of Defence retains the right to withhold information if it deems that releasing it would pose a national security risk (as explained in Q29) and often exercises it, means that it is probable that there are omissions within these submitted reports. Further, the fact that the legislature is fully controlled by the ruling party also suggests that parliament is not independent of the executive. Therefore, score 1 has been selected.

Peer Reviewer one: some information is available in parliament archives (see above cited source). Agree that parliament is fully dominated by the ruling party. Comment updated and source added. Score changed from 2 to 1.

Researcher4689: There is no evidence of a law that allows or prohibits off-budget military expenditures in Ethiopia. The Ministry of defence and armed forces have to disclose their accounts to the Auditor General, but can withhold these details from all actors, including the Auditor General, if it is deemed sensitive to national security. So it is impossible to know the extent to which these expenditures do take place.

A rare study on military budgeting in Ethiopia alleges that the budgeting process of the Ministry of Defence is the same as other ministries with non-budgetary expenses. However, other sources have not been found to verify this claim. Therefore, score 1 has been selected.

Response to reviewers: agree. Comment updated and source added. (Peer reviewer 1: the original score was 1 already. I have elaborated on the comment to justify the score).

Researcher4689: Since this would be kept secret from the public, I have not seen seen any evidence of off-budget activity or its legality. Sources in government told me that this sort of information (related to military expenditure) would under no circumstance be revealed to the public, as it is deemed sensitive to national security. It is well known however that the military has off-budget income in the form of security assistance from countries such as the US and international peacekeeping.

A SIPRI study however lists Ethiopia as one of the African countries where military expenditure including off-budgets are hidden 'either with the collaboration of the parliament or through manipulation at the finance ministry'.

Peer Reviewer 2: disagree. There is complete lack of transparency with regards to off-budget expenditures and no information about the government's activity to address corruption in this area. Score maintained.

Researcher4689: On matters of information classified on the basis of national security, Art. 23 of the Freedom of the Mass Media and Access to Information Proclamation states:

'The public relations officer may refuse a request to access information or a request to confirm the existence or non-existence of a piece of information, if the disclosure or confirmation of the requested information would be likely to cause prejudice to the security, defence and international relations of the country.'

Such requests are likely to follow due process, in that they pass through legal bodies; however, as with many of the issues raised so far, effective scrutiny is unlikely to take place given the informal merger of the party and state system which does not allow for truly independent oversight (see Pambazuka article above).

Peer Reviewer 1: agree. Comment updated and source added. Score changed from 3 to 2.

Researcher4689: These businesses are treated as other public enterprises, and are audited by the Auditor General. Information about them is publicly available.

The major example is a sizable conglomerate called the Federal Metal and Engineering Corporation (METEC) that grew out of the defence industry complex. METEC coordinates all electro-mechanical projects in the country, at times actively implementing projects and at other times subcontracting to both local and international companies. The logic of having the military take the leading role in this industry is that the military is the only segment of the government that has well established metal and engineering experience.Although this initiative was quite recently announced, already METECT has about 16 subsidiary organisations which altogether have over 100 factories under them. METEC is now without doubt the biggest, richest and most influential enterprise in the country at the moment.

Further, METEC is beginning to diversify it's business portfolio. It has started to acquire private property and hotels, the 'Imperial Hotel' in Addis Ababa being one example.

Just like other state owned enterprises there is no evidence that METEC's annual reports have ever been made available to the public. METEC's exact financial and budgetary links with the military is not entirely clear (see Peer Reviewer 2's comments below).

Given the size of these enterprises and the lack of transparency around the exact financial linkages between the military industrial complex and the military, score 1 has been selected.

Peer Reviewer 2: disagree. The Reporter explains that &quoute;the long term vision is to enable the military to cover its expenses on its own and generate income to the country. &quoute; suggesting that METEC, among other entities, will accomplish this. Score 1 maintained.

Researcher4689: Military owned businesses are audited internally by the defence Ministry, then by the Ministry of Finance and Economic Development, and finally by the Office of the General Auditor. The detailed reports are not available to the public, rather, only the aggregated numbers for each sector and ministry are released.

The auditing capacity and performance of the government has come under some criticism from local media for their lack of sufficient resources and effective implementation although this does not directly review the performance of the Office of the General Auditor (Addis Fortune).

Response to reviewers: agree. Score changed from 3 to 2.

Researcher4689: There is only one case of this which has appeared in the media recently, involving a now-retired army major who was part of an illegal organisation using fake identities allegedly in order to acquire 460sq. metres of land in Addis Ababa. The individual and a number of others were charged by the Federal Ethics and Anti Corruption Commission’s prosecutor, for &quoute;corruption of power and preparing a fake document&quoute;. The major was sentenced to three years in prison (the others on trial were freed), and the land reclaimed by the government, indicating that sanctions are in place and can be applied when offenders are caught (see article above).

My opinion is that transgressions are likely to be rare and when they are caught then they are likely to be tried in a manner that doesn't get publicized.

The lack of other cases in the media could be for many reasons: because these transgressions are rare, because there are poor oversight mechanisms or due to the fact that such cases, even when sanctioned, are kept within the defence establishment rather than widely publicised. However, as seen above, when someone has been found to engage in such activity by anti-corruption agencies legal measures are taken against those individuals.

Researcher4689: Officials do regularly point out that corruption is a serious threat to the functioning of the government and defence sector, and commit to combatting it - General Samora Yenus, for instance, listed corruption as one of the three main threats facing the army (Ethiopian Opinion). This includes the Chief of Staff of the Armed Forces as well as the head of the military corporations.

Researcher4689: There have been cases of high-level arrests (as can be seen from the articles above), which cover a range of personnel, from law enforcement officers charged for misappropriating cartons of shisha (FEAC article above), to the former director general of the Ethiopian Revenues & Customs Authority charged with losing the government over 800m Br in revenue (Addis Fortune) or the former head of internal intelligence at the Ethiopian National Intelligence and Security Service (NISS), charged with abuse of power (Ethiopian Reporter). However, such measures are inconsistently applied.

Investigations together with the Federal Ethics and Anti-Corruption Agency are conducted and resulted in prosecution of individuals from the security sector. The extent to which these are indiscriminately and consistently applied are unclear. However when someone has been found to engage in such activity by anti-corruption agencies legal measures are taken against those individuals.

Peer Reviewer 1: disagree. Evidence exists that measures are in place for personnel found to have taken part in forms of bribery and corruption (see comment above) even though they are not always consistently applied. Score maintained.

Researcher4689: The business Anti-corruption Portal states that: 'Article 444 of the Criminal Code, Proclamation No.414/2004 provides legal protection [to] whistleblowers. Article 7, sub-article 16, of the Federal Ethics and Anti-Corruption Commission Establishment Proclamation states that the Commission shall have the powers and duties to provide physical and job security protection to witnesses and whistle-blowers. Further, another proclamation was passed in 2010 to provide for the protection of whistleblowers.

Several sources note that whistleblowers are continuously providing information on graft and corruption to the Federal Ethics and Anti-Corruption Commission (FEACC) and that civil servants are well protected from recrimination and other negative consequences when reporting corruption. In practice, however, Global Integrity 2010 assesses the de facto protection of both public and private sector whistleblowers as inadequate. According to the FEACC, whistleblowers can present their complaints of alleged corruption offences in person, by telephone, fax, e-mail or letter; the FEACC will not disclose their identity without their permission. Reporting mechanism numbers can be found on the FEACC website'.

While this is in regard to whistleblowing in general, it is doubtful that it is implemented within the defence Sector, as most whistleblowing cases reported in the media are from other sectors of government. No public evidence of statements made by the MOD regarding whistelblowing could be found. While the army may welcome whistleblowing within its own structures, it is less likely that details of these would be released to the media or public at large; rather it would be dealt with from within the establishment. Therefore, score 1 has been selected.

Response to peer reviewer 1: agree. Comment and sources updated, score changed from 2 to 1.

Researcher4689: Section 2/4 of Proclamation No. 27/1996, which concerns recruitment, does not say anything about personnel in sensitive positions, and nor do the clauses on promotion. A new proclamation from 2013 provides specifics on age of retirement, rotation and criteria for promotion however there is no indication that special attention is paid to personnel in sensitive positions. Therefore, score 1 has been selected.

Response to peer reviewer 2: agree. Comment updated and score changed from 4 to 1.

Researcher4689: There is no evidence published that details the exact composition of personnel in terms of civilian and military. There are numbers published, however, on the ethnic and regional composition of the armed forces. But these are given in percentages and not exact figures.

IISS in 2014 published that the aggregate number of military personnel of Ethiopia to be 138,000; but there is further information here on civilians in the defence sector.

Score 1 has been selected as even though it may be known to the Ministry of Defence, the Ethiopian government does not make the size and composition of its armed forces and local militias public.

Response to peer reviewer 1: disagree. Given that the establishment has given the percentage of ethnic composition in the army, it is reasonable to conclude that the number if known to the establishment.

Response to peer reviewer 2: Agree. Comment updated and source added. Score changed from 2 to 1.

Researcher4689: The defence Ministry does not publish such information; indeed, in accordance with Art. 72 of Parliamentary Proclamation 55 (1), it can withhold it if it so sees fit. When individuals are charged for criminal offences, their individual salaries may be revealed during the proceedings.

Researcher4689: The Ministry of defence do not publicly provide any information on its salary scales or procedures. It is worth noting, however, that despite this lack of transparency, there have been no cases in the media about soldiers complaining about irregularities. Academic studies on the defence sector do not mention this either.

The high levels of security threats in the country has made the security sector relatively well-resourced and effective. It is thus very likely that salaries are paid regularly and according to fixed rates.

Researcher4689: There are understood to be established systems and procedures for promotion for military personnel, although these details are not made public and normally have to be requested from the MoD.

Appointment and promotion of the top leadership is mostly made public, and this has shown that the leadership of the army remains dominated disproportionally by former liberation fighters from the TPLF and are from the Tigray region. The lower rungs are more balanced ethnically and appointments are understood to follow more meritocratic principles, although there is no evidence that appointments are not based on political loyalty.

Score one has been selected as the appointment system is not published and it is not clear what level of oversight governs the appointment system. Further, the top leadership are still dominated by a single ethnic group, whilst there is no evidence that middle level management is not based on loyalty to the party ideology.

Response to peer reviewers: agree. Comments and sources updated. Score changed from 3 to 1.

Researcher4689: Promotions are understood to be effected through formal appraisal processes and promotion boards. In addition, the newly amended proclamation of the Defence Forces Act has further regularised military promotion processes and systems.

However, there have been complaints about the implementation of such procedures, particularly with regards to new recruits, and relating to the accountability of those leading these processes (See Teweldemedhin). Additionally, there is very little available information about the exact processes involved, the oversight mechanisms used, and if these processes take place independent of the chain of command. Therefore, score 1 has been selected.

Response to reviewers: agree. Comment updated and sources added. Score changed from 3 to 1.

Researcher4689: There are no policies of compulsory recruitment in Ethiopia and no accusations thereof as far as I know. Compulsory conscription only happens during emergencies, the last of which was the Ethiopia-Eritrea war (1998), and even then it was solely from the population along the border. There is no publicly available evidence that suggests that there is a policy against accepting bribes for avoiding conscription. However, conscription is very rare, therefore score 2 has been chosen.

Researcher4689: Armed Forces recruitment is entirely voluntary, except for cases of emergency.

Score 2 has been chosen as conscription is extremely rare in Ethiopia. Furthermore, there is a policy with meritocratic criteria on recruitment procedures generally; however, this does not explicitly mention deterrents against bribery or corruption. There are however general anti-corruption and ethics policies within the armed forces. One study found that 69% of interviewees and participants in a focus group found recruitment processes to be transparent. There are thus problems in these procedures but they are mostly conducted according to regulations.

Researcher4689: The government employees I interviewed mostly held the view that this would be unlikely. But there is no transparent system of enforced accountability in payment systems within the MoD that is open to public scrutiny.

The strict nature of discipline within the armed forces and the tight defence budget in relation to size of the defence forces makes the extensive existence of ghost soldiers very unlikely.

Researcher4689: The civilian and military components are separated in the defence sector, with the civilian led ministry in charge of all budgetary and monetary matters. There is no publicly available information on whether or not this is a policy or just practice. Peer reviewer 2 raises important concerns regarding what the systems may be like in more remote areas of the country but there is no evidence that this is the case in pratice or to the contrary. Therefore, score 2 has been selected.

Response to reviewers: agree. Comment updated. Score changed from 4 to 2.

Researcher4689: According to interview with a government official, the defence Ministry does have a special Code of Conduct on corruption and bribery, but they do not release any detail on this information and, therefore, it is difficult to gauge how comprehensive it is.

There is also a general asset and disclosure proclamation that applies to all government officials that covers ethics of civil servants as well as disciplinary measures, but not post-separation activities. Further, Proclamation No.414/2004, The criminal code of the Federal Democratic Republic of Ethiopia criminalises corrupt behaviour in any public sector employee.

Peer reviewer 1: in the absence of public evidence I have interviewed a relevant interviewee. Score maintained.

Researcher4689: There are a few publicised instances where punitive measures were taken against breaches of the Code of Conduct - the cases given above detail a general who was prosecuted for obtaining land illegally using faked identities (The Ethiopian Opinion) and the prosecution of the former head of Internal Intelligence of the National Intelligence and Security Services (NISS) for abuses of his power (AllAfrica).

However, as publicised cases are infrequent, and the code remains unpublished, it is difficult to know the extent to which the code of conduct is being enforced. In addition, such prosecutions are often related to rivalries within the government, and are inconsistently applied; all these factors together mean that this question is scored at a '2'.

Researcher4689: The Ministry of defence's recent annual report to the standing FDSAC mentions several training sessions on anti-corruption being given to a cross-section of military personnel, but the report does not give further details of how often this occurs, or whether it is a regular and institutionalised occurrence.

Given that anti-corruption measures are institutionalised through the deployment of an official in each agency particularly for this purpose, it is likely that regular anti-corruption training takes place.

Researcher4689: There are only a few cases which have gained public attention, and they, including the two above which both feature military officials caught abusing their power, involve politically controversial individuals, raising doubts as to whether they were truly only prosecuted for corruption reasons. The low number of cases that go public suggest either that there either are only a few transgressions and prosecutions or that more prosecutions do happen but are kept secret rather than released to the public; It is impossible to know for certain which of these explanations are more correct, given that we have no concrete information about those that are potentially kept secret.

Investigations by the public prosecutor and Federal Ethics and Anti Corruption Commission are conducted and resulted in prosecution of individuals from the security sector. The extent to which these are indiscriminately and consistently applied are unclear. In other words, these high-level prosecutions have correlated with power struggles taking place within the government.

In conclusion, there have been cases of high-level arrests and persecution, but no known policy that they ought to be made public. There is some speculation that these may be politically driven and not just for ethical purposes. Therefore, score 2 has been chosen.

Researcher4689: Facilitation payments are illegal in Ethiopia and are punishable with up to ten years in prison. Training on anti-corruption, as mentioned in Q49, potential deterrent effects of whistle-blowing, and possible investigations by the FEACC are measures that are used to mitigate facilitation payments.

However, there is little indication that these mechanisms are effectively used or capable of discouraging occasional facilitation payments. The Business Anti-Corruption Portal states that facilitation payments are common in Ethiopia, although to a slightly less degree compared to other countries in the region. The TI corruption index gave Ethiopia the rank of 33 indicating a relatively high perception level of corruption in the public sector. However, it is not clear if this applies to the defence sector as much as other more public facing parts of the government (local administration, etc.). Therefore, score 3 has been selected.

Researcher4689: Corruption is not mentioned specifically within the national security strategy, and there is no publicly available information that it is mentioned on military doctrine as a strategic threat in operations. However, the Chief of Staff of the armed forces has publicly mentioned corruption as one of three strategic challenges that could dismantle the army.

The allocation of ethics and anti-corruption officers in each agency as well as regular training on anti-corruption is indicative of corruption being considered a strategic problem as well as the awareness about this amongst the armed forces. Therefore, score 2 has been selected.

Peer Reviewer 2: disagree. There is no publicly available information that the military specifically address corruption as a strategic risk in operations. Score maintained.

Researcher4689: There is no evidence that there is anti-corruption training for commanders specifically focused on operations. However, in its recent report to the Parliamentary Standing Committee, the Ministry of Defence stated that it has conducted anti-corruption training on all levels within the military as well as assigned anti-corruption and ethics officers among the military. However, the extent to which individuals act on this is impossible to gauge from this information. Therefore, score 2 has been selected.

Researcher4689: No academic studies, media or government statements were found which discuss corruption allegations or awareness about the the potential for corruption in peacekeeping missions. They do, however, mention that there is a great deal of pre-deployment training and institutional infrastructure which supports the peacekeeping missions, such as the Ethiopian Peace Support Training Center (EPSTC).

Anti-corruption measures are institutionalized through the deployment of an official in each government agency particularly for this purpose. The Federal Ethics and Anti Corruption Commission enforces anti-corruption measures across government. It may therefore be that corruption monitors are deployed. However, it is simply unclear whether or not corruption monitors are deployed and therefore score 1 has been chosen.

Researcher4689: Peacekeepers are given specific training at the Ethiopian International Peacekeeping Training Centre, while all staff within the defence Ministry are trained by the Ethics and Anti-Corruption Directorate. However, it is unknown whether the specifics of this training include addressing corruption risks in contracting whilst on deployed operations or peacekeeping missions. Therefore, score 1 has been chosen.

Researcher4689: There is no evidence that PMCs are banned by law in Ethiopia. However, no academic study or media report mentions such contractors, they have also not been part of discourse around defence issues in Ethiopia or mentioned in anecdotal observations. Military training or support of any sort to Ethiopia comes from other state-actors. Therefore, score 3 has been selected as it is very unlikely that PMCs are employed in any way but there appears to be no legal ban against their use.

Peer reviewer 1: the article referenced is about private security companies not PMCs. These are very different. Please see peer reviewer 2's comment's below. Score maintained.

Researcher4689: The Public Procurement Manual applies to all Federal Government ministries and agencies. But according to Article 3 of the Proclamation, the Minister 'may, in the interest of national security or national defence, decide to use a different procedure of procurement and property administration, in which case the Minister shall define by a directive the method of procurement and property administration to be followed in order to serve the interest of economy and efficiency'.

There is no specific procedure for the defence ministry in this case, other than that the Minister can exempt certain items from formal procedures based on national security, and where national security is cited, the public cannot know about these processes. Therefore, score 1 has been selected.

Response to reviewers: agree. Score changed from 0 to 1.

Researcher4689: The procedures and regulations for federal procurement are publicly available (and cited above), but information on specific procurement isn't disclosed. The proclamation from the federal procurement agency states that information concerning proceedings shall not be disclosed unless ordered by a court or higher authority.

The MoD's assessment of needs, contract implementation and sign-off are not disclosed to the public.

Researcher4689: The Auditor General, the Ethics Department within the defence Ministry and the parliamentary standing committee on Foreign, defence and Security Affairs are all responsible for scrutinizing whether all aspects of monetary spending are conducted according to plans and regulations. As these are not publicized in detail however, it is difficult to know their effectiveness.

There are oversight mechanisms, and they are likely to be somewhat active. However, they are not transparent. Therefore, score 2 has been selected.

Researcher4689: Details of defence spending are considered sensitive to national security, and, as the Defence Ministry have the right to withhold any information considered sensitive to national security (as detailed in Q29), only aggregate numbers are presented to the public.

Researcher4689: There are no unique regulations and procedures for the Ministry of defence. The Federal Procurement Directive applies to all Executive elements of the government, including the MoD. Nor are there any unique requirements on tenders from the MoD.

According to the directive, before entering the bidding process the public body has to prepare a document providing 'An indication that the bidder has to sign on Anti bribery pledge form; a statement of undertaking to observe Ethiopian Law against Fraud and Corruption and other forms that ought to be completed and signed by him/her' (art 16.4).

Researcher4689: Implemented procurement processes are not revealed to the public for national security reasons. There is, however a publicly available national security strategy that guides defence policy, and against which every policy must be justified. The policy is now dated (it came into effect in 2002). However, this may not necessarily result in opportunistic purchases (see comments by peer reviewer 2 below). Therefore, score 2 has been selected.

Researcher4689: Implementation of procurement processes are not revealed to the public for national security reasons.

However, the security sector under EPRDF has been tightly controlled by the political leadership, and as per the national security policy, defence spending and practice is to be planned, organized and on a needs basis.

So while there is no public evidence providing insight into this aspect of the organization, based on an overall assessment of the state and party, the MoD and armed forces are likely to conduct defence purchase based on quantified and clearly identified needs.

Researcher4689: Like all government agencies, the Ministry of defence's procurements are supposed to be conducted through open competition (see proclamation no. 649/2009). However, the MoD have the authority to withhold information deemed sensitive to national security and can therefore legally single-source their procurement, if the Minister deems this necessary.

A considerable amount of the MoDs logistical procurement is conducted through public open competition tenders (see 2Merkato).

However, given the level of secrecy in the sector score 1 has been selected.

Response to Peer Reviewer 1: agree. Comment updated. Score changed from 2 to 1.

Researcher4689: There are regulations and codes in place for the board regarding procedures of tendering, as detailed in Chapter 4 of The Ethiopian Federal Government Procurement and Property Administration Proclamation (cited above). There is no information here, however, regarding its implementation. In addition and as stated previously, the MOD can invoke national security at any time and not abide by these processes. Therefore, score 1 has been selected.

Response to reviewers: agree. Comment updated and source added. Score changed from 3 to 1.

Researcher4689: There are national laws against collusion in general (see Parliamentary proclamation 649/2009 above), but no legislation which is specific to the defence sector. And no media news was found discussing the implementation of these laws by prosecution in the defence sector. Therefore, score 1 has been selected.

Peer Reviewer 2: agree. Comment edited.

Researcher4689: Like the rest of the state apparatus, defence procurement officers are likely to be organized into a department, with some staff shortages. Given the sensitivity and the general discipline of the sector, there is likely to be good oversight, with minimal undue influence. However, the department is likely to be characterized by poor training and staff shortage. However, there is no publicly available information on this therefore score 1 has been given.

Researcher4689: There are formal mechanisms in place for allowing companies to complain about perceived malpractice; they can submit a formal complaint which will be reviewed by members of a board consisting of five senior government officials, including the Minister for Defence (according to Art. 36 of the directive cited above).

In some cases, there is evidence of actual complaints lodged and action taken by the government in reaction although this is not in the defence sector (see Sodere.com source above). It is unclear whether there are mechanisms in place protecting against potential discrimination in future bidding, as it is not mentioned in the legislation.

Score 2 has been chosen as there is no evidence about the effectiveness of these mechanisms in the defence sector.

Peer reviewer two: agree. Comment updated and score changed from 3 to 2.

Researcher4689: The Federal Procurement Directive states that:
&quoute;48.5.1 If it is proved that a bidder or supplier has committed one of the acts listed below with an intention to distort or alter the bid evaluation result or during the contract administration, he/it may be suspended from the supplier’s list for a period not less than two years or for an indefinite period, so that he/it may not participate in any public procurement for the period for which the suspension lasts.
....
Without prejudice to any action that may be taken by the Agency on a supplier or bidder, public bodies shall be entitled to seek compensation for any damage or loss they have sustained on account of an act or omission by a supplier or bidder in connection with any procurement in accordance with the contract or the law.&quoute;

There is evidence that these sanctions are applied in non-defence contracts (see list of debarred companies in the Public Procurement Agency website) but there is no available information on defence contracts per se. Therefore, score 2 has been selected.

Response to Peer reviewers: agree. Comment updated and source added. Score changed from 3 to 2.

Researcher4689: There are no any anti-corruption policies specifically focused on offset contracts. The regulations on off-sets from the civil code do not mention anti-corruption.The procedures of particular deals and negotiations are also not publicized. The Ethiopian federal financial administration proclamation stipulates that all financial transactions should be contractual and according to regulations. Based on the operation of the rest of the bureaucratic apparatus, it is my opinion that standard contractual and auditing requirements also apply to off-sets.

Peer reviewer 1: disagree. In the absence of sources I have used broader federal financial administration proclamation and practice to award a score of 1. Score maintained.

Researcher4689: This information is not revealed to the public in any form. Furthermore, none of the interviewees I spoke to with intimate knowledge of the government's actions are familiar with particular instances of offset contracts.

My opinion, based on expert knowledge of the country and sector, is that these are likely to exist, but I cannot say anything else substantial about them.

Researcher4689: There are no specific competition policies on offset contracts. According to the interviewee, when/if they take place, the process is likely to be kept as a secret (like all military contracts), and not be disclosed to the public. The low score here reflects the lack of transparency surrounding the process.

Researcher4689: There is no formal policy on the use of intermediaries.

When/if intermediaries are used, they are likely to be individuals that are well known to the officials hiring them, and thus informal restrictions are likely to be in place - but no formal restrictions.

The TI Government Index 2013 assessment had indicated that the government had systems in place for controlling company's use of agents and intermediaries in the procurement cycle. However, there is no publicly available information that could corroborate this. Therefore, score 1 has been selected.

Researcher4689: Such activities are deemed sensitive to national security and not published to the public.

Researcher4689: There is no mention of sub-contractors in the Federal Public Procurement Directive.

Since this not a policy, it is highly unlikely that bureaucrats implementing procurement laws in general will take the initiative to encourage this informally.

Researcher4689: Ethiopia has been importing predominantly from Ukraine, with which it has no political connections. Hence in this case, it is highly unlikely that procurement decisions have been affected or influenced by the exporting country. The purchases from Ukraine and other countries in Eastern Europe have to do with the fact that the bulk of the Ethiopian military hardware are inherited from the Soviet Era. Therefore, although the government does not disclose its military planning, needs or purchases in public, it is possible to conclude that there is minimal seller country influence in defence procurement.

However, Ethiopia is an important ally of the US in the 'war on terror' . Ethiopia has close military relations with the United States and Israel, and it has received donations of military equipment, or subsidised purchases, from these countries.

Therefore, Score 3 has been selected.

Response to peer reviewer 2: agree. Comment updated and sources added. Score changed from 4 to 3.