Georgia

The provisions for asset disposal are clear [see Law on State Property and Presidential Decree on Procedures for Asset Disposal] and the usual practice follows them. If the MOD decides to sell or transfer assets, these are given to the Ministry of Economic and Sustainable Development, which is responsible for disposing of the assets either through direct sale or auction. All funds received from the sale of property or equipment are transferred to the central budget. However, the MoD does not yet have a unified, comprehensive system for consolidating the information about its existing supplies and assets. To address this problem, the MoD has started working on a software program and electronic database and this process is coordinated and supervised by a special working group. This software will be compatible with NATO systems and linked with MOD procurement software.

Scrutiny of this area falls within the remit of the State Audit Office, which has recently been engaged in an audit of the MoD.

According to interviews conducted at the MOD by the NATO Peer Review Team, the MOD has identified asset disposals as one of the areas at greatest risk of corruption and bribery. Although asset disposals are independently scrutinised (by the State Audit Office), the results of such scrutiny are not available publicly, though the SAO's report is available to Parliament once the audit is complete. If the MOD decides to sell of transfer assets, these are given to the Ministry of Economic and Sustainable Development, which is responsible for disposing of the assets either through direct sale or auction. All funds received from the sale of property or equipment are transferred to the central budget.

According to the interviewed Parliamentarian, in the 2013 budget year, the percentage allocated to secret items (MOD, MIA and Special State Protection Service) was 5.8% of total defence and security expenditure. This figure has been driven down in recent years by reforms and initiatives within the MOD to reduce the number of confidential purchases and single source procurements. For example, previously, in 2012, even boots were a classified purchase. In 2012, 73.7% of total MOD expenditures were classified, in 2011, 87.7%. The majority of procurement conducted by the State Intelligence Service is still secret, although SIS spending is relatively small: 5 million GEL in 2013 (2.88 million US dollars). Ministry of internal Affairs total procurement in 2013 was 132 000 000 GEL, secret expenditure was 27 000 000 GEL, equivalent to 20.4 % of total procurement and 4.7% of the MIA’s total Budget (570 000 000 GEL). This data is published in the MOD White Books.

In 2013, the MoD initiated a legal amendment (which was passed) requiring the Minister of Defence to report annually to Parliament concerning MoD expenditures in the reporting year. Full details on confidential spending information are given to the Group of Confidence, a sub-committee of the Defence and Security Committee. According to the interviewed Parliamentarian and to media reports, while the mechanism is working and full information is being supplied, the Group of Confidence underwent procedural and membership changes in in early 2014, 18 months after a new government had assumed power; thus it may not have been able to exercise meaningful scrutiny throughout the government's tenure. In February 2014, Parliament simplified the rules regarding the composition of the Group of Confidence (previously many ruling Georgian Dream coalition parliamentarians had refused to support one candidate, nominated by the opposition UNM party). The final composition of the Group of Confidence was approved by Parliament in May 2014.

Grade 3 selected as the Group of Confidence could be much stronger in performing its role. For example, neither the DSC nor the Group of Confidence were consulted about a recent major arms procurement deal (air defence systems) and were only informed after information was officially requested, and after the deal was concluded. (7, 8)

According to the Law on Security Service, intelligence agencies should report annually about their activities to the parliament and their representatives should attend the hearings at the respective committees. As for the Group of Confidence, according to the law its direct responsibility is the budgetary control of secret activities and special programs conducted by the state executive agencies.

There is no publicly available evidence, for example in the minutes of DSC, that audit or any similar documents on security sector have been provided or considered by the committee. No audits of intelligence services specifically are available publicly. According to the interviewee, the DSC reached an agreement with the State Audit Office in early 2014, specifying that in addition to formal annual reports, the SAO will also provide the DSC with specific reports on secret programs of the MOD, State Security and Intelligence Services. The DSC has the power to call and question officials if required. Debate is limited to the DSC. Secret items are reviewed by the Group of Confidence. However, the Group was re-established in May 2014, following procedural and membership reform, thus this process is only just beginning and this mechanism has yet to prove itself. Since it is impossible to say how detailed the information received by the Group is, score 2 has been selected.

Interviewees confirmed that there are no off-budget military expenditures, all defence-related expenditures are recorded in the official defence budget. No information could be found on off-budget expenditures on the web-sites of any of the organisations – legal entities of public law – that are under the control of the Defence Ministry.

According to an interview with a Parliamentarian, there are no off-budget military expenditures. According to them, should any information or allegations of off-budget expenditure come to light, the Inspectorate General of the MOD would investigate the issue and a report on that incident would be posted on the MOD Inspectorate general website.

The classification of information is legally regulated with provisions made for who can request information to be classified on the grounds of protecting national security. The 2015 Law on State Secrets defines the categories of classified information and states that the heads of government departments, or those nominated by them, are responsible for classifying information; the Government approves the list of information that can be classified as a state secret. The Law also contains the types of information that may and may not be classified, including a list for defence-related information. Scrutiny over classification and access is provided by the judiciary and the parliamentary Group of Confidence, whose scrutiny is currently weak partly due to its recent reconstitution and procedural reform.

The interviewed senior members of the MoD state that in previous years they have known of senior individuals, or individuals closely connected to the leadership, being able to influence decisions. According to one interviewee, &quoute;We believe that currently there is too much power given to the President to classify information on the grounds of national security. The provisions are clear but too wide, there is too much discretion.&quoute; The 2015 update to the Law on State Secrets, meant to address these issues, was criticised by TI-Georgia as 'significantly expand[ing] the range of normative acts that can be classified as secret.' (6)

Prominent NGO, the Georgian Young Lawyers Association issued a statement pointing to &quoute;the necessity to review the list of information that is &quoute;deemed to be classified&quoute; and the frequent use of the formulation &quoute;prejudice the national interests&quoute; as the only basis for classifying information.&quoute;

Ownership of commercial businesses appeared to have be largely forbidden by legislation. Commercial exceptions to the law, such as Delta (Arms Factory) and The Aviation Factory, which were previously managed and owned by the MOD, were moved to the Ministry of Economy and Sustainable Development in March 2014. This information was confirmed by interviewees, media sources and NATO Peer Review Team Report. However, as of August 2015, control of the Delta Arms Factory was moved back to the MOD. As this is a very recent development, its significance and the governance of the enterprise could not be assessed in detail, and no recent audits of the enterprise are available.

Ownership of commercial businesses appeared to be largely forbidden by legislation. Commercial exceptions to the law, such as Delta (Arms Factory) and The Aviation Factory, which were previously managed and owned by the MOD, were moved to the Ministry of Economy and Sustainable Development in March 2014. This information was confirmed by interviewees, media sources and NATO Peer Review Team Report. However, as of August 2015, control of the Delta Arms Factory was moved back to the MOD. As this is a very recent development, its significance and the governance of the enterprise could not be assessed in detail. The most recent audit of Delta dates back to 2014, when the centre was audited by the State Audit Office. The results were not publicized as they were classified. (7) It is unclear what the situation will be under MOD management.

There is evidence of previous unauthorised private enterprises by senior military employees and that the sanctions for breaking these laws are weak or often not enforced if the individuals involved are powerful figures. A 2013 report published by TI Georgia (Businessmen in Politics and Politicians in Business: the problem of revolving door in Georgia) noted that, &quoute;Companies connected to former defence Minister Davit Kezerashvili (Defence Minister 2006-2008) had a near complete control over the Georgian TV advertising market until 2012&quoute;; these companies held licenses for outdoor advertising in Tbilisi. The Minister's asset declaration did not reflect his direct or indirect control over a number of companies, some of this received large government contracts (including at least GEL 86 through noncompetitive procurement on gasoline procurement) between 2010 and 2012. (3) Kezerashvili claims the charges are politically motivated, he currently resides in France, an application by the Georgian prosecutor to extradite him was refused by a French court in February 2014.

Both interviewees confirmed that for the past two years there has been no evidence of unauthorised private enterprise owned by military or other defence ministry employees. The NATO Peer Review Team noted that all Georgian officials down to department head level (to include family members) must file annual property and financial declaration with the Civil Service Bureau. However, this system does not at present have any monitoring mechanisms in place. In 2013, the Government has committed to develop and implement an asset declaration monitoring system within the framework of the National Anti-Corruption Action Plan and Open Government Partnership. The system has been set up, but the monitoring procedures are still being developed. (6)

RESPONSE TO GOVERNMENT REVIEWER: As the asset declaration and monitoring systems are relatively new and it is unclear to what extent instances of unauthorised enterprise could be effectively found, score 2 maintained.

There are examples of a clear commitment to anti-corruption and integrity measures by the Defence Ministry, as declared by the Defence Minister, the Chief of Defence, and Single Service Chiefs. In July 2015, Deputy Minister of Defence Besik Loladze stated that “It makes no sense to talk about justice in corrupt environment,&quoute; stressing commitment to anti-corruption. Defence Minister Tinatin Khidasheli has not been as vocal in stressing the importance of anti-corruption measures as her predecessor (other than general commitments in terms of NATO integration), but in her former capacity as Head of Parliamentary Committee of European and Euro-Atlantic Integration, the Khidasheli stated that there should not be any loopholes in legislation that might allow any illicit or non-justified intervention in business, especially from the public authorities in Georgia. However, this commitment is reflected throughout the defence ministry and armed forces by other senior ministry staff and senior armed forces officers in speeches and through a number of specific measures such as the reforms program that is underway at the MOD, joining NATO's &quoute;Building Integrity&quoute; initiative, a new national Anti-Corruption Strategy and related MOD BI Action Plan 2014-2015.

The Georgian Criminal Code (Articles 338-339) criminalises passive and active bribery of public officials. Sanctions include fines and imprisonment for instances of bribery and abuse of influence, and the list of persons covered by the provisions was extended following an OECD monitoring report. (4) According to interviewees, effective measures are in place for personnel found to have taken part in forms of bribery and corruption, but they have not found any cases of solicitation of bribes. There were some malpractice cases and instances of negligence and inefficiency; some staff were sanctioned while some were dismissed and others were officially warned, or their salary was temporarily reduced. Detection of these issues is the primary task of the Military Police, Inspectorate General and the newly formed Internal Audit Unit. However given that the standards within the Military Police were felt to be too low (as noted previously) and the MOD is making a concerted effort to re-hire and re-train staff, this role could be fulfilled to a higher standard.

A legal framework for whistle-blowing was introduced in 2009: article 20 of the Law of Georgia on the Conflict of Interests and Corruption in Public Service guarantees the whistleblower legal protection and is applicable to all civil servants. In April 2014, amendments were made to the legislation, introducing a presumption of confidentiality for the identify of whistleblowers and strengthening protection against retaliation or intimidation for the whistleblower and their close relatives. The amendments also state that disclosures could be submitted in writing or orally, through fax or telephone, etc. However, shortcomings remain: whistleblowers under protection are current or former officials and protection is not extended to volunteers or private sector employees, and there are no guarantee of compensation being paid to whistleblowers in case of discrimination or retribution. (3) The law also does not require that institutions introduce specific internal mechanisms for whistleblower disclosure and does not specify the types of disclosures that are protected. (6)

Moreover, the Georgian laws state that whistleblowers within the MOD and the Ministry of Internal Affairs are to be protected by internal regulations, and these have not been adopted as of mid-2015. (6) The MOD has taken some actions to encourage whistleblowing: in May 2013, a special hotline was installed by the Inspectorate General which allows MoD personnel and civilians to inform the IG about any violations in the defence system. In addition, complaint boxes were installed in every military unit throughout Georgia. According to their internal statistics these whistle-blower mechanisms are now being used and becoming more widely known. The Building Integrity Training Course (a pilot course was last run in September 2014) introduces the topic of whistleblowers and whistleblower protection; according to the BI Action Plan this training will eventually be rolled out to all military and civilian employees. (2) However, lack of specific legal mechanisms remains a significant loophole and justifies the score of 2, further supported by lack of evidence that these issues are indeed treated seriously by the MOD.

Special attention is now starting to be paid to personnel in sensitive positions and the mechanisms for selection and oversight are being developed. According to a senior official at the MOD, an analysis of sensitive positions has been performed across all areas; there has been open recruitment for these posts and they are prioritised for BI training. (2, 3) The BI Peer Review Report noted that while a Concept Paper on Human Resource Management and Professional Development and an Action Plan for reforming the human resource management system have been developed, there was still no requirement for a security clearance requirements for those occupying sensitive positions. (1)

Score 2 has been selected as the sensitive positions have not been declared and the rules of selection and oversight are not yet clear.

According to the 2013 budget there are 43,475 MOD employees: 37,825 military personnel and 5650 civilian personnel. The number of civilian and military personnel is publicly available on the MoD's website.

Pay rates and allowances for all civilian and military personnel are now openly published on the MOD's website. Minister's Order #560 (26th September 2007) regulates pay rates and allowances for civilian and military personnel and is available on MOD's website in Georgian in the Legal Documents section.

A 2012 review of salaries and allowances for military and civilian personnel resulted a tightening of regulations on supplements to salaries, which were previously decided on by the Minister of Defence. Currently bonuses are prescribed in a Defence Minister’s Order and include hazardous duty, control of classified information, flight pay, etc. In January 2013, allowances for soldiers deployed in Afghanistan were raised significantly. Finally, introduction of a pay-by rank system is currently planned to replace the existing pay-by-position system. Tables of organisation and military job descriptions are in place and financial calculations necessary to implement this new system are completed.

A media search identified no evidence of delays in payment to any military or civilian personnel. According to an interview with a Parliamentarian, no complaints have been received from personnel regarding delays in payment. As pay rates are announced, basic pay is non-discretionary. The 2015 National Integrity Study confirms that salaries for civil servants have been paid on time.

This area has been a focus of reform since the change of government and the establishment of a dedicated deputy Minister of Defence to oversee reforms in human resources and education (3). In 2013, the NATO Peer Review Team noted significant shortcomings in the area of human resource management. The MOD developed a Concept Paper on Human Resource Management and Professional Development and an Action Plan for reforming the system. Priorities for reform included: appointments procedure; performance evaluations; promotions, professional development, and management processes and procedures.

In 2013, the MOD established selection boards composed of military and civilian members (such as the dept. minister) with set criteria on how people are selected for appointments or for promotions (education both military and civilian, awards received, acknowledgements, military career etc.). Candidates are scored on all criteria and then ranked; the highest scorer is nominated for the position. The criteria are pre-defined and not created anew for each job. The MOD invites NGOs to attend and observe the interview process for civilian roles (confirmed by all interviewees). There are also external advisors such as the American CUBIC team, paid for by the US Department of Defence. This entire process is now done outside of the chain of command.

Through 2014, selection boards ensured selection of personnel for promotion, appointment to relevant positions and participation in various study courses abroad. Up to 60 Selection Board meetings were held in 2014, evaluating 2083 candidates and selecting 1349 individuals. (8)

RESPONSE TO GOVERNMENT REVIEWER: Agreed. Score changed to 4.

Personnel promotions are effected through formal appraisal processes and promotions boards. Such processes are publicly declared. However, it is unclear if promotions to senior ranks are open to scrutiny by independent personnel.

This has been one of the MOD's priorities for reform; in 2013, the MOD established promotion boards for military advancement with independent testing. (1, 2) According to a senior member of the MoD (see also NATO Peer Review Report, 2), it only established position and rank–based qualification requirements defining criteria, numbers and skills necessary for the promotion of military personnel in 2010. Civilian personnel promotion decisions are now made by a special commission established by the Defence Minister which interviews nominated candidates and then makes promotion decisions. The decisions of the selection process are recorded in an official protocol signed by all commission members. Special Selection Boards have been established in the Joint Staff to take decisions on assignments, promotions, and participation in military training courses abroad which are more than one month in duration. The decisions of these commissions are based upon clear and objective criteria (education, career path, evaluations, awards received, and physical fitness) and are documented in official protocols. This was noted by the NATO Peer Review Team, in December 2013, as an example of good practice: &quoute;The use of promotion boards for military advancement and the use of independent testing with a balanced interview process using selection panels in the hiring of new civilian staff.&quoute;

From 2014, it is planned to establish a new centralised military personnel distribution and assignment system. A personnel promotion system will also be established based on the principles of fairness, objectivity and transparency, according to the NATO Peer Review Team. The BI Action Plan (see above) includes the following reforms to be carried out by the Human Resource Management and Professional Development Department in 2014-2015: &quoute;1) Developing and adopting the Civilian Office Human Resource Management Development Strategy by Q2, 2014; 2) Adopting the Military Personnel Management Development Strategy by Q2, 2014; 3) Developing a new system for performance evaluation in the civilian office of the Ministry of Defence by Q4, 2014; 4) Putting into practice the new performance evaluation system in the civilian office of the Ministry of Defence Q4, 2015.&quoute;

The 2014 MOD White Paper states that officers` and NCO position qualification requirements were renewed and the Military Personnel Promotion Concept paper was approved. The new system of promotion is to ensure promotion of military personnel in fair ways. Through 2014, selection boards ensured selection of personnel for promotion, appointment to relevant positions and participation in various study courses abroad. Up to 60 Selection Board meetings were held in 2014, evaluating 2083 candidates and selecting 1349 individuals.

RESPONSE TO GOVERNMENT REVIEWER: Score 3 selected as it is unclear if there is oversight of senior promotions by independent personnel.

In 2007 the then government stated that it would end compulsory conscription and move to a fully professional army. That this would occur by 2017 was reiterated by the former Minister of Defence in 2013. The Defence Academy had previously taken on school graduates, often from poor families and orphanages, including 17-year-olds, but since 2005 the Academy has restricted entry to graduates. Conscription numbers have been falling as more volunteers sign up for the military, under reforms designed to bring the armed forces more into line with the NATO model of highly-trained professional soldiers, rather than the Soviet-like conscript army. However, state funding will be an issue in ending conscription, as it is much cheaper to hire conscripts than professional soldiers. Despite this, in practice, there is very little incentive to pay a bribe to avoid conscription as citizens are legally permitted to pay money in order to delay conscription for 2 years. In addition, soldiers' pay (starting at 800 laris, around 470 US dollars per month) as well as the recent reforms, have made serving in the military an increasingly attractive employment opportunity.

There are general (non MOD specific) strict policies and laws against bribery (mostly contained in the Criminal Code which criminalises active and passive bribery of public officials), but they are not directly related to compulsory conscription. According to interviewees, there are effective procedures in place to act as a deterrent and there have been no instances of bribery occurring in the last two years. There were some malpractice cases related not fulfilling duties effectively, inefficiency etc. and some staff were sanctioned while some were dismissed and others were officially warned, or their salary was temporarily reduced.

Preventing and detecting corruption is the primary task for the Military Police and Inspectorate General; according to interviewees, in 2012 the Military Police dealt with 16 corruption cases and in 2013 with 57 cases. Interviewees stated that effective measures are in place for personnel found to have taken part in forms of bribery and corruption but they have not found any cases of solicitation of bribes. The details are published on the MOD website and in the press.

There are general (non MOD specific) strict policies and laws against bribery (mostly contained in the Criminal Code which criminalises active and passive bribery of public officials), but they are not directly related to refusing bribes to gain preferred postings in the recruitment process. According to interviewees there are effective procedures in place to act as a deterrent and there have been no instances of bribery occurring in the last two years. Investigating cases of suspected bribery is the primary task for the Military Police and Inspectorate General. In 2012 the Military Police dealt with 16 corruption cases and in 2013 with 57 cases. The details are published on the MOD website and in the press.

The findings of the NATO Peer Review Team in December 2013 are also of relevance to a risk assessment of this area. One example of best practice highlighted is the use of selection boards for promotion for both military and civilian staff, and the boards also decide participation in military training courses abroad which are more than one month in duration. The commissions' work is guided by clear criteria, including education, career path, evaluations, awards received, and physical fitness (the criteria were established in 2010); official documentation exists to reflect the processes.

There is no recent evidence of ghost soldiers or reported problems in the media or according to interviewees. The internal audit unit was only recently established (early 2014) and is not yet fully active. Since December 2012, the Inspectorate General has investigated a number of violations committed under the previous MoD leadership including a small number of cases of employment of “ghost” personnel. Upon completing its investigations, the Inspectorate General held press conferences to inform the public about the identified violations. The Inspectorate General has forwarded its documentation to the State Prosecutor’s Office for further investigation, which is still ongoing.

RESPONSE TO GOVERNMENT REVIEWER: Agree, score revised to 3.

Chains of command are strictly separated from chains of payment throughout the ministry and armed forces. According to the NATO Peer Review Assessment Team, the MOD's Finance Directorate is tasked with calculating salaries and allowances, preparing payroll, and maintaining records. A 2012 review of salaries and allowances for military and civilian personnel resulted a tightening of regulations on supplements to salaries, which were previously decided on by the Minister of Defence. Currently bonuses are prescribed in a Defence Minister’s Order and include hazardous duty, control of classified information, flight pay, etc. In January 2013, allowances for soldiers deployed in Afghanistan have been raised significantly.

Finally, introduction of a pay-by rank system is currently planned to replace the existing pay-by-position system. An action plan has been approved and is currently being implemented (see BI Action Plan) and a phased transition to a pay -by-rank system, beginning with officers, was introduced from 2014. A transition to the pay-by-rank system for NCOs is expected to take place in 2015. Tables of organisation and military job descriptions are in place and financial calculations necessary to implement this new system are completed. The J1 (personnel department of the Chiefs of Staff) and Financial Department are currently elaborating a chart which will incorporate net pay, service increments and all types of bonuses to ensure more transparency and better understanding of the actual pay rates of MoD personnel for the public sector.

Strictly speaking, at this moment there is no code of ethics for MOD civilian personnel and one of the recommendations made by the NATO Peer Review Team to the MoD in December 2013 was to develop a Code of Conduct which would be understandable, which would cover issues of gifts and hospitality, and which would include provisions for regular training. The BI Action Plan stated that a Code of Ethics for civilian employees would be developed by the Resource Management and Professional Development Department by mid-2014, along with staff training and implementation and monitoring mechanisms. Information at the time of finalising the assessment indicates that the Code has been elaborated and approved, but it has not been made public yet.

Currently, there is a Presidential decree (#111) which regulates the appropriate behaviour of military personnel and defines disciplinary sanctions and penalties. Military personnel receive special training in the laws which regulate discipline upon initial entry into service, as well as within their units during their entire period of service. Civilians are required to be aware of Civil Service laws regarding conflict of interest and corruption prior to employment by the MoD, and general rules of conduct in public sector, including for the civilian staff of MOD, are defined by the Law on Public Service. Additionally, the MoD Human Resource Management and Professional Development Department is putting together an Employee Handbook. The handbook will provide information which will include corruption and integrity related regulations from the laws of Georgia. Once finalised, the handbook will be distributed to all MoD employees.

It is too soon to assess whether breaches are effectively addressed, currently monitoring for many of the issues likely to be covered in the Code is the primary task of the Military Police and Inspectorate General. According to interviewees, effective measures are in place for personnel found to have taken part in forms of bribery and corruption but they have not found any cases of solicitation of bribes. There were some malpractice and negligence cases, and some staff were sanctioned while some were dismissed and others were officially warned, or their salary was temporarily reduced. Some of the results of these are publicly available on the MoD's website. The Parliamentary Defence and Security Committee may request information about disciplinary sanctions and the MOD is obliged to deliver this.

RESPONSE TO GOVERNMENT REVIEWER: There is no policy to make outcomes of prosecutions publicly available. Score maintained.

Regular anti-corruption training is at the early stages now that the Building Integrity (BI) Program is underway. Since April 2014 a BI training syllabus has been piloted; according to the MoD this will gradually be rolled out and training will ultimately be delivered to all military and civilian staff and repeated on at least an annual basis, according to interviewees (see also BI Action Plan and NATO Peer Review report).

According to a senior member of the MoD: &quoute;The BI training syllabus is being piloted from the end of April 2014, beginning with sensitive positions, then including all mid level staff, eventually all staff in military and civilian positions, it will be intensive and routine anti-corruption training. Each course will have 15-20 people. In addition the National Defence Academy added a BI course to its bachelor program at the beginning of 2014, and in the military school, anti-corruption training is beginning to feature in all curricula.&quoute; Furthermore, three trainees from the Georgian MOD attended TI UK's Defence & Security Program Offices in London for a training secondment on devising and implementing this anti-corruption policy, one returned in October 2014 for a 'Train the Trainer' session and will assist in teaching the BI course in Georgia.'

In July 2015, the Building Integrity and Minimizing Risks of Corruption training course was held for the fourth time at the Defence Ministry on July 22, 2015. The seminar is organized by the HR and Professional Development Department of MoD, PDC of National Defence Academy and NATO Liaison Office.
Training course on anti-corruption issues is underway at the Ministry of Defence of Georgia in the framework of NATO Building Integrity Program.

Grade 2 selected as this training is not yet fully rolled out to all staff and there is no conclusive evidence that it is regularly repeated.

There have been, recently, more examples of outcomes being made public, for example on the MOD’s website, or in the media. There are examples available of effective prosecutions in recent years: in 2012 the Military Police dealt with 16 corruption cases and in 2013 with 57 cases. The details are published on the MOD website and in the press, with one recent example being the developments in the so-called 'Cable Case'. (7)

According to senior officials in the MoD, in previous years, some individuals were prosecuted but others were not for illegal activity in the MoD and in their opinion this depended on that individual's connections to those in power. There are recent examples of senior figures being prosecuted, for example the recent trial of Bacho Akhalaia, former Minister of Defence, and a failed extradition request by Georgia for Davit Kezerashvili, who served as Minister of Defence prior to Akhalaia, for charges of corruption, money laundering and bribery.

Facilitation payments are strictly illegal and mechanisms to punish offenders are in place and are effectively applied. Georgian Criminal Code (Articles 338-339) criminalises passive and active bribery of public officials. Sanctions include fines and imprisonment for instances of bribery and abuse of influence, and the list of persons covered by the provisions was extended following an OECD monitoring report. (6) No exceptions are made in the law for facilitation payments; therefore, it can be concluded that these are prohibited. (7) Both interviewees confirmed that facilitation payments were illegal and that the problem of small bribes was effectively overcome within the Georgian administration.

There is no specific military doctrine on how to address corruption issues for peace and conflict, and there is no systematic collection of lessons learned or a specific doctrine to address anti-corruption matters. But the armed forces are aware of corruption as a strategic issue for operations, see White Book and other documents on the MoD's website, and a training programme is beginning to address the issue. The NATO Peer Review Team noted (evidence was collected in Q4 2013) that while there was no specific pre-deployment training or doctrine, Military Police officers were deployed to monitor corruption-related risks and incidents in the field. In 2014, Building Integrity (Anti-Corruption) training has begun and soldiers serving on foreign operations, such as ISAF Afghanistan (see link) have been prioritised to receive this training. There is no written doctrine as yet, but a clear awareness of corruption as a strategic issue on operations.

In March 2014, the GAF started providing the Building Integrity (Anti-Corruption) training to commanders at all levels serving on foreign operations, such as ISAF (in Afghanistan) and the mission in Central African Republic. According to the MoD, this is to become routine for all military and civilian staff, on an annual basis. Pre-deployment training on corruption risks during military operations was held for the infantry group of 31st battalion, 3rd brigade. Similar training sessions are planned for the rest of the military forces slated to participate in international military operations.There is no evidence of corruption issues being mishandled in theatre.

Trained professional Military Police officers capable of monitoring corruption in the field are regularly deployed and regularly report on the status of corruption within mission. Their reports are made available in the Inspector General's Annual Report to Parliament, but are not currently available to the public. According to the NATO Peer Review Team, Military Police personnel were deployed to Iraq and Afghanistan and no incidents of corruption were identified during those operations.

According to a report by the NATO Peer Review Team published in December 2013, there were no specific guidelines regarding procurement in conflict environments. There are no planned reforms for this area in the BI Action Plan. In 2014, Building Integrity (Anti-Corruption) training has begun and soldiers serving on foreign operations, such as ISAF Afghanistan (see link) have been prioritised to receive this training. So far, training on corruption risks during military operations was held for the infantry group of 31st battalion, 3rd brigade, and similar sessions are planned for other units slated to participate in international military operations. (4)

RESPONSE TO GOVERNMENT REVIEWER: A Ministerial order appears to allow personnel to make emergency purchases with a pre-determined amount of money. Moreover, even if personnel are under others' command, this does not mean they should not be aware of corruption risks in the supply chain, as they might come into contact with it.

Private military contractors are not employed. The Constitution of Georgia describes provision of defence as the exclusive prerogative of the state and can be construed as precluding the employment of private military firms (Article 3, Paragraph 1(c)). This has been confirmed by interviewees.

All state procurement is regulated by the Public Procurement Law, except for items classified as a state secret as defined in the Law on State Secrets and except for items below a certain value: article101(3) provides for the 'simplified procurement' procedure for procurement objects with a value of up to GEL 5 000 (or with a value of up to GEL 50 000 by Georgia’s diplomatic missions and consular offices abroad, or objects related to defence, security and maintenance of public order with a value of up to GEL 20 000 if the contracting authorities operate within the system of the Ministry of Internal Affairs of Georgia and the State Security Service of Georgia, the Ministry of Defence of Georgia and by the Special State Protection Service of Georgia). However, there do appear to be gaps in implementation. The NATO Peer Review team stated that the exemptions could easily be abused and specific procedures which would prevent bids from being geared toward one contractor are still not in place. (1)

According to a June 2013 report by TI Georgia, the electronic State Procurement System, which was launched in 2010, is of very good quality; however, it is bypassed due to exemptions granted to entities such as the Government’s and President’s Reserve Funds and the Ministry of Defence, which sign contracts without going through the platform. The MOD has only recently begun using the online platform. (2)

Independent scrutiny of defence spending has improved in the last 2 years (the 2013 TI Georgia report had stated that little information was available on MOD procurement). According to a report published by the NATO Peer Review Team (also confirmed by interviewees), legal amendments which will require the MOD to notify the Defence and Security Committee about any planned open procurements exceeding two million GEL (900,000 Euros) for goods and four million GEL for construction services, were adopted. The Group of Confidence was named as the body scrutinising classified procurement. Moreover, the Defence Minister is now required to report to Parliament on all MoD activities expenses by the end of each year. However, the parliamentarian interviewed stated that while the MOD fulfils obligations stipulated by the law, the Committee usually receives a 'very short' report where details of procurement are not provided; the Committee has requested, on several occasions, that the MOD supply more detail.

In May 2015, Minister Khidasheli appointed Davit Ebralidze as First Deputy Defence Minister responsible for finance, logistics and procurement, he also serves as Parliamentary Secretary of the Ministry.

MOD procurement is planned and administered by its State Procurement Department through a centralised system. According to the White Book 2014, the MOD announces tenders using the electronic system of procurement and places information on the web-pages of both the State Procurement Agency and MoD (in the section specifically dedicated to tenders) to ensure maximum transparency. Representatives of the non-government sector actively supervise the process of procurement by monitoring these web pages and attending tender commission sessions at the invitation of the MoD. This is the practice for all open (non-confidential) procurement; the MOD has increased the use of open tenders dramatically since 2012, while greatly limiting the numbers of confidential bidding procedures.

In this way, for non-confidential tenders, the defence procurement cycle process, from assessment of needs, through contract implementation and sign-off (but not asset disposal), is disclosed to the public. A further change (for non-confidential procurements) initiated in 2013 is that NGOs are invited to attend tender board meetings. For confidential procurements, further transparency has been added by the three legislative amendments mentioned above: these procurements are meant to be reviewed by the Parliamentary Group of Confidence.

However, as highlighted by the NATO Peer Review Team, the MOD needs to develop a new acquisition and budgeting planning system which encompasses appropriate planning guidance, to ensure that the system is utilised, monitored and accountable. To this end, the MOD has set up a Resource Management Working Group composed of department and division heads responsible for resource planning, procurement, and financial management. This group is responsible for developing the MoD’s program budget for 2014-2017 (a government requirement).

Further transparency is currently limited by the Law on State Secrets. It is unclear to what extent the 2015 amendments to the Law will enable the MOD to minimise the use of urgent procurements, significantly reduce the number of classified procurements, elaborate more detailed acquisition administrative instructions and more actively engage civil society organisations in monitoring the process of open procurements.

There are two separate mechanisms depending on whether a tender is classified, in which case oversight is provided by the Parliamentary Group of Confidence, or non-classified, in which case oversight is provided by the Procurement Agency’s Dispute Resolution Board and by the Defence and Security Committee). The Procurement Agency's Dispute Resolution Board is active, transparent and independent. The MOD now routinely uses the e-procurement platform for most of its procurement needs, and all of these tenders can also be scrutinised by the Defence and Security Committee. The State Audit Office also has the right to examine public contracting, however, no recent reports on the MOD were located. The MoD Inspectorate General is required to also regularly monitor the procurement process, although, according to the NATO Peer Review Team, it has not been as effective as was anticipated, with 7 audits into procurement procedures conducted in 2012-2013. There are also continuing issues regarding the division of competences between the Inspectorate and the Internal Audit, which could well diminish the effectiveness of both departments. (1)

TI Georgia has described the Dispute Resolution Board (DRB) as an effective structure allowing tender participants to file appeals on specific decisions; the DRB can oblige the contracting entity to suspend or cancel the procedure in question. The composition of the DRB - including representatives of the State Procurement Agency and civil society organisations - helps ensure impartiality and independence, as does publication of rulings and other relevant information such as tender specifications, online. Overall, the DRB provides an effective institutional layer against corruption and malfeasance in procurement. (4)

Public oversight is made possible by the availability of relevant information online: in 2013, TI Georgia was able to spot potential irregularities and inappropriate personal relations and company structures in relation to two tenders published by the MOD via its electronic procurement system. (3)

There are, however, shortcomings in oversight by the Group of Confidence, which was reconstituted and reformed in early 2014. The Group of Confidence were not consulted about a recent major arms procurement deal and were only informed after information was officially requested, and after the deal was concluded. (9, 10)

Score 2 has been selected as these mechanisms are relatively new and untested, and shortcomings remain in parliamentary and SAO oversight of the MOD.

The State Procurement Law mandates that all procurement procedures over 200,000 GEL (90,000 Euros) is to be conducted, by law, via an electronic tender, (5) and all actual, non-confidential purchases are made public on the State Procurement Agency electronic procurement system. As of 14 November 2013, 230 tenders were announced worth over 196.5 million GEL. From announced tenders, contracts were signed for 98 tenders with a value of some 47.7 million GEL (20.3 million Euros); confidential contracts were signed in the amount of 32.8 million GEL (13.9 million Euros) in 2013. Any procurement over 200,000 GEL (90,000 Euros) is to be conducted, by law, via an electronic tender. As noted above, all of this information, including the tender specifications, winning bidder's offer and contract, final price, final contract etc. are published and available online. As noted previously, since 2013 the MoD is now legally required to notify the Defence and Security Committee about any planned open procurements exceeding two million GEL (900,000 Euros) when procuring goods and four million GEL when procuring construction services. In the case of closed procurement, the MOD is required to submit information to the parliamentary Group of Confidence. In addition, at the end of each year the Minister is required to report to Parliament on all MoD activities and incurred expenses. However, neither the DSC nor the Group of Confidence were consulted about a recent major arms procurement deal and were only informed after information was officially requested, and after the deal was concluded. (7, 8)

But otherwise, there is very limited information available regarding potential purchases. According to an interview with a senior member of the MoD, &quoute;From 2015 we hope to be in a position to be able to publish a three year procurement plan in the Strategic Defence Review; currently we are working on a one year plan.&quoute; Current strategic-level documentation does not contain detailed procurement plans. However, a parliamentarian highlighted (and the media reported on) that large, potential purchases are often discussed in public forums. For example, &quoute;A plan to sell off old Soviet-made military helicopters and acquire modern ones was openly declared by the MOD, and became a matter of public discussion including civil society organisations and think tanks, the final decision is not made yet, but it is a good illustration that every issue related to arms import/export is subject to the public discussions and debate.&quoute;

RESPONSE TO GOVERNMENT REVIEWER: Score 4 cannot be selected as there is very little information about forward defence purchases. Score 3 maintained.

No requirements are placed on companies beyond what is generally in company law. The State Procurement Agency maintains a black list of suppliers banned from participating in tenders and a 'white list' of those who have been approved; this, however, has not come with specific requirements or criteria. (1) The SPA in 2014 was developing a ranking system to rank all known suppliers and their contractual compliance (including defence suppliers); however, this is not yet launched.

This area is listed as a reform in the BI Action Plan, which postulates that required anti-corruption standards for companies should be introduced for companies participating in MOD tenders. This was to be finalised by the end of the first quarter of 2015; however, as of mid-2015, there is no evidence of progress being made. (1)

Georgian security and defence policy is shaped by a number of strategic-level documents, including the Strategic Defence Review 2013-2016 and the National Military Strategy 2016. Both of these documents list capability gaps; the NMS, for example, mentions the necessity to develop self-propelled artillery and acquire air-defence systems. The recent purchase of air defence systems from a French company (6, 7) thus appears to be in line with the major defence planning assumptions.

Neither of the strategic documents, however, provides a high level of detail. Moreover, the general weakness of defence and procurement planning systems makes it well nigh impossible to assess how effective the flow of information from the strategy to particular procurement decisions (in terms of, for example, technical specifications) is. The 'Building Integrity Self Assessment peer Review Report Georgia' (1) states that building up a 'viable, efficient and effective procurement process' is still a challenge and a top priority for the MOD. More specific goals include elaboration of more detailed procurement guidelines, reduction in the number of confidential procurement procedures (and better regulation of those that still occur), and unplanned procurement audits by the first quarter of 2015. As for mod-2015, however, there is no evidence of progress being made.

RESPONSE TO GOVERNMENT REVIEWER: Due to the weakness of the planning processes which should connect the strategy with individual procurement procedures, score 2 has been selected.

According to a senior MOD official, past abuses had included purchase of low-quality and damaged equipment, embezzlement and document falsification and illegal acquisition of items for political purposes, all of which revealed weaknesses in the requirements quantification process and oversight.

Recent developments include the introduction of a standardization and codification system elaborated to improve planning and implementing of procurement process. Internal coordination was refined to increase the number of publicly available electronic purchases; up till mid-2015, 418 electronic and simplified electronic tenders were announced under the state budget allocations (in total 34 842 990 GEL). (6, 7)
The procurement and needs quantification chain goes as follows: first, requests for procurement go from the brigades to the operational commands. One copy of the request is forwarded to the Logistics Support Command, one copy goes to the J4 Department and one copy is sent to the State Procurement Department. If the requested item is not in stock, the command forwards the request to the J4 and State Procurement Department. The State Procurement Department starts the procurement process by elaborating a procurement plan which defines the quantity of items and services to be procured, identifies retail prices and services, and produces the final procurement information. The final procurement plan is reviewed by the Head of the State Procurement Department who, in turn, submits the plan for approval to the responsible Deputy Minister. After receiving approval, the Head of the Department tasks the appropriate Procurement Manager to initiate the regulated procurement procedures.

A working group is currently engaged in developing a programme-based budget for the MOD for 2014-2017 and to develop detailed procurement plans based on priorities set by the SDR Implementation Plan and the Minister’s Vision 2013-2014. This should further improve the process of setting requirements.

Score 3 has been selected as there is no direct evidence of recent opportunistic and unplanned purchases, but it is also unclear to what extent previously identified shortcomings had been addressed.

The Georgian Law on Public Procurement enumerates 'healthy competition' between tender participants among its principles and stipulates that tender requirements should be formulated in a way that enhances competition. (4) The MoD has increased the use of open tenders dramatically, while greatly limiting the number of closed bidding procedures. This has greatly improved transparency and this trend is expected to continue to be a major goal of the MoD.

The NATO Peer Review Team noted that the number of participants in MoD electronic tenders was above the average for Georgian government agencies and the number of electronic tenders announced in 2013 rose by over 800% in comparison to previous years. In 2013, about 22.4% of the MOD procurement budget was earmarked for confidential procurement and therefore likely single-sourced. (1)

According to the interviewed Parliamentarian, &quoute;The percentage of spending on secret items of total defence and security expenditure in 2013 budget year allocated to national security and the intelligence services is 0.54%. In 2013 MoD has spent 167 826 000 GEL on 1010 contracts (goods and services), from which only 149 contracts worth 42 418 000 GEL were secret. It is 25.3% of total MOD procurement and 6.4% of total defence expenditures. If we take the whole picture into consideration it is a significant step forward comparing the percentage of secret contracts of total MOD procurements in 2012 (73.7%) and (87.7%) in 2011.&quoute; The 2014 the MOD White Book also shows that the number of open tenders has seen a large increase as compared to previous years (in 2011 there were only 32 open tenders; in 2014, 484 open tenders were announced. (5)

An electronic tender is administered by a tender commission composed of at least three representatives of the MoD (normally heads of departments), including a Deputy Minister and supported by a secretariat within the MOD. The commission can invite subject matter experts and consultants (which can include NGOs) to observe its actions; they do not, however, have the right to vote. The commissions' decisions on tenders are guided by the criteria included in the tender announcement and publicly available. A member of the commission who disagrees with a tender decision has the right to submit their differing opinion in writing.

The Law on State Procurement provides regulations on conflict of interest for members of tender boards. Close relatives of the directors of bidding companies and their shareholders cannot be appointed as members of a tender commission; close relatives of the heads and employees of bidding companies cannot be invited to participate in the planning, implementation or supervision of procurement or to serve as experts or consultants, and that commission members, experts and consultants are required to confirm in writing that their participation in the procurement process did not violate any of the relevant regulations. There are currently no further laws or MOD regulations pertaining to tender boards.

The State Procurement Agency has an independent auditing function, performed by the Dispute Resolution Board, which audits tender board decisions for SPA tenders when triggered by complaints. The Dispute Resolution Board’s decisions are seen as independent and are automatically published.

RESPONSE TO GOVERNMENT REVIEWER: Score raised to 3 as audits are complaints-based.

There is no legislation specific to defence and enforcement of measures to punish colluding companies is only weakly enforced. There is a general law prohibiting collusion and other actions against free competition, but according to a report by Transparency International - Georgia, &quoute;the Competition and State Procurement Agency (CSPA) has been unable to effectively exercise oversight of competition for more than a year now. To date no cases of unlawful restriction of competition on the market or of violation of Georgian competition law have as yet been investigated or initiated by the Competition and State Procurement Agency.&quoute; The BI Peer Review report notes that limited experience of the MOD staff in administering open tenders means that implementation of procurement regulations has had significant room for improvement.

RESPONSE TO GOVERNMENT REVIEWER: Indeed, the number of open tenders administered by the MOD rose significantly. However, it has not been possible to verify whether there is sufficient expertise and experience to identify and sanction potential collusion between suppliers. Score maintained.

The MOD has a specialised unit responsible for procurement – the State Procurement Department, whose competences and tasks are described in the MOD's Statute. (3) Procurement staff are expected to ensure that defence contractors meet their obligations, but there is limited training, this area is now a focus of reform within the ministry. The NATO Building Integrity report noted that staff have limited experience in administering open tenders and recommended further training (particularly for staff in the Procurement Department and members of tender commissions) combined with designing a more comprehensive acquisitions procedures.

If the goods or services delivered do not correspond to the provisions of the tender, sanctions available include fines, reimbursement of fees, and debarment (the State Procurement Agency is to maintain a list of both blacklisted and accepted companies).

RESPONSE TO GOVERNMENT REVIEWER: Noted and the score is indeed somewhere between 2 and 3. However, it takes time for a new department to become effective and for training to yield benefits; thus for now, score 2 has been maintained.

Formal mechanisms defined by the Law on State Procurement are in place to allow companies to complain about perceived malpractice in procurement. Before assigning the status ‘completed’ to the electronic tender, companies participating in the procurement are allowed to appeal the actions of a procuring agency or a tender board either to the procuring agency itself, to the Dispute Resolution Board of the State Procurement Agency (SPA) or to the judiciary if they believe that their rights or interests were violated. The procuring agency is required to suspend the procurement process during the adjudication of a complaint. If a complaint is filed with the SPA and it finds that the claim is valid, it is authorised to order the procuring organisation to revise its decision. The SPA is required to review a complaint and inform an appellant about its decision within ten working days from receiving the complaint. This decision is made public and is posted on the SPA website. The SPA may raise the question of responsibility regarding the agency concerned with the relevant law-enforcement institutions. The procuring agency also has ten working days to review a complaint and inform an appellant about its decision. Decisions taken by procuring agencies and the SPA can be challenged in court. As of November 14, 2013, 33 tenders have been contested with a range of decisions taken as to their resolution. The Law on State Audit authorizes the State Audit Agency to scrutinize the decisions of the appeal boards.

The appeal decisions as well as all relevant information including tender specifications are made public by the Dispute Resolution Board. The Board has 6 members, 3 from the SPA and 3 from civil society organisations; this, according to TI Georgia, ensures impartiality and independence. The transparency of the process and the public availability of information is an additional security mechanism for companies and can act as a mechanism to prevent corruption. (4) The Law on State Procurement, Article 23, defines a person that has the right to file a complaint vaguely as an entity interested in participation. In practice, the SPA interprets this provision in a broad sense, allowing any interested organization or citizen who might be spotting a violation of the law to file a complaint (for this, registration on the website is required). The report by TI Georgia also states that while the appeal mechanism is not yet widely known, the number of complaints has been increasing, which indicates trust in the system and the perception that stakeholders using it would be protected from discrimination.

Score 3 has been selected to reflect the relatively recent establishment of these mechanisms, which means that their effectiveness cannot yet be comprehensively assessed and there are no clear provisions stating that genuine complaints cannot be discriminated against.

A range of sanctions are available, from procurement executive-imposed debarment to legal sanctions, but such sanctions are only sometimes applied in practice. The Georgian Criminal Code contains provisions regarding the liability of legal persons and sanctions can include a prohibition on pursuing a particular line of work. However, the OECD has noted that there had been very few cases of prosecution of legal persons and that the area needed improvements. (4)

For the majority of tenders that are procured publicly via the e-procurement platform, the State Procurement Agency can put a company on its Black List and ban it from participating in public contracting for one year. Companies are blacklisted after a government entity files a complaint against a supplier that has failed to deliver on its contract (1, pp. 6-7). The Black List is publicly accessible on the front-page of the SPA website. However, according to Transparency International Georgia, the Black Listing system is not properly implemented and gaps exist. One example was the case of Greenservice, a company providing tree planting services which continued to participate in tenders despite being on a blacklist (it only changed its name to Greenservice+). The company was the sole tendered in one instance; prices were reported to have been inflated and the company's board included former mayor of Tbilisi and a deputy head of a district administrative body. (2) It thus appears that the system can be circumvented by the simple measure of changing the company's name, which creates risks for defence procurement as well.

According to the Building Integrity Self Assessment Peer Review Report Georgia (December 2013), the MoD does not engage in any offset programs. No evidence to the contrary has been found.

According to the Building Integrity Self Assessment Peer Review Report Georgia (December 2013), the MoD does not engage in any offset programs. No evidence to the contrary has been found.

According to the Building Integrity Self Assessment Peer Review Report Georgia (December 2013) the MoD does not engage in any offset programs.

The MoD does not currently use agents or intermediaries for procurement, but their use is not forbidden and use of agents and intermediaries by companies is not regulated or forbidden. The MOD Building Integrity Action Plan of the MOD 2014-2015 includes a number of initiatives which may have a bearing on the use of agents, including limiting the number of urgent procurement procedures and enhancing transparency; currently, however, this is not a regulated area.

RESPONSE TO GOVERNMENT REVIEWER: The focus of the questions is also on the regulations which apply to companies. Since no evidence of any regulations was found, score 0 was maintained.

Financing packages surrounding major arms deals are not publicly available prior to the signing of contracts. In 2014, the former Minister announced an intention to replace some military helicopters, but negotiations with suppliers are underway and little information is available. In 2015, existence of a major arms deal on air defence systems to be provided by a French company was only revealed after the contract was concluded, and the terms of the contract have not been made public. (4-6)

There is no evidence of the government formally requiring the main contractor to ensure that its subsidiaries and sub-contractors adopt anti-corruption programmes, nor is there evidence of the government encouraging this informally. According to the interviewed parliamentarian, the government does not formally require that main contractors and sub-contractors to adopt anti-corruption programs.

This is a reform listed in the BI Action Plan, &quoute;Introducing mandatory anti-corruption standards for Ministry of Defence procurement bidders (companies) by Q1 2015.&quoute; However, no formally approved standards or regulations have been located.

There have been no significant defence acquisitions since 2013 and purchases made so far seem to have been made independently of political pressure. Media articles suggest that the USA - Georgia's largest foreign donor - remains the most desired weapons provider. But this does not appear to be strongly supported by the purchasing data available on the SIPRI Arms Transfers Database, which records that from 2008 to 2011, Georgia purchased the following conventional weapons: 24 guns from Bulgaria; 12 Self-propelled MRLs from Czech Republic; 100 APVs, 70 APCs and 2 Patrol craft from Turkey; 104 SAM systems from Ukraine and 70 APCs from the USA. Most of these purchases were made in 2008 when Georgia was at war with Russia for 5 days. Since 2011 there have been no recorded purchases by Georgia.

More recent statements made by Minister Alasania suggest the MOD intends to replace its ageing Soviet helicopter fleet; according to interviews, negotiations are ongoing with a range of potential suppliers including France, the USA and, according to another interviewee, UK-based suppliers. With limited resources, its likely the MOD will seek heavy discounts from what its considers its closest allies. More recent articles suggest that purchases will be made from the USA: U.S. defence Secretary Chuck Hagel visited Georgia in September 2014, and on the agenda was Georgia's planned purchase of American military helicopters. The deal for Blackhawk utility helicopters has been in the works since at least 2012. But this is the first time it seems to have been discussed publicly, and the two sides seem to be getting close. (5) The recent air defence deal was signed with France.

Recent changes in the procurement process, including the introduction of a standardisation and codification system and basing detailed procurement plans on priorities set out in strategic documents (9), should further diminish the risk of seller influence.