On 19 December 2018, the public discussion of the “Draft RA Anti-Corruption Strategy and Action Plan for its Implementation for 2019-2022” (hereafter referred to as Strategy” was organised in cooperation with the RA Ministry of Justice in the scope of the EU-funded “Commitment to constructive Dialogue” Project implemented by the Armenian Lawyers’ Association NGO ((hereinafter referred to as the ALA) with participation of the organisations representing the CSO Anti-Corruption Coalition of Armenia and representatives of other civil society organisations.

It should be noted that invitations to participate in the public discussion were sent to a number of state bodies and NGOs. In addition, information about the event was spread through social networks (invitees’ list is available here, the list of participants is available here, the invitation for participation in the event published in Facebook is available here).

Despite the fact that the Draft Strategy needs a radical revision, however the CSO Anti-Corruption Coalition of Armenia welcomes the commitment of the Ministry of Justice to a constructive dialogue and to ensure a participatory and transparent process for the elaboration of the Draft Strategy aimed at having a consensus document as a result. This practice is assessed positively as compared to previous anti-corruption strategies. Moreover, the previous, “2015-2018 Concept for Fight against Corruption in Public Administration System”, which was the basis for the anti-corruption strategy, was developed in the conditions of the “highest secrecy” (details on this are available here). The concept was developed by the working group created without any legal basis, whose work was co-ordinated by the assistant of the ex-president. Unfortunately, the non-governmental organisation also participated in the development of the above-mentioned concept.

Referring to the draft Strategy, it should be noted that on 19 December 2018, the Ministry of Justice of the Republic of Armenia published the Draft Strategy on e-draft.am – the unified website for publication of legal acts drafts.  The deadline for submission of proposals was initially set on 3 January, 2019, further extended to 8 January. At this stage, CSOs develop their recommendations to improve the draft strategy.

In this respect, taking into consideration the issues raised by the participants during the 19 December public discussions, as well as the limited deadlines for presenting comments and suggestions on the latter, on 20 December, 2018, the Armenian Lawyers’ Association, applied with a letter to the acting Prime Minister of the RA Nikol Pashinyan, suggesting to set realistic deadlines for the development of the “Draft RA Anti-Corruption Strategy for 2019-2022” aimed at revising and further development  and finalisation of this draft document, conducting expert discussions with the involvement of public at large.

The Coalition positively assesses the Government decision represented by the RA Ministry of Justice to extend the term of the Public Discussions on e-draft.am website, setting it up to 31 January, 2019.

At the same time, several non-governmental organisations also expressed their opinion on the Draft Strategy presented for public discussion. It is worth mentioning that these organisations have reflected in their opinion on the draft to specific provisions of the Draft Strategy and noted that the draft does not comply with of the requirements of the Methodological Guidelines for elaboration of Concepts, Strategies and Programs approved by the Protocol Resolution No. 2 of the RA Government Session on 22 January, 2015. In this regard, it is worth mentioning that the above-mentioned Protocol decision of the Government of the Republic of Armenia has been revoked by point 2 of Protocol Resolution No. 42 of the RA Government session of 5 October, 2017, thus the application of the requirements of revoked Protocol Resolution of the Government of the Republic of Armenia on the Strategy drafted by the mentioned organisations are unlawful and unreasonable.

We also note that in the near future, the CSO Anti-Corruption Coalition of Armenia will publish a package of proposals on making changes and additions to the Draft Strategy.

Armenian CSOs’ Anti-Corruption Coalition

09.01.2019