Annual Review - Summary Sheet Title: Support to the World Bank project ‘Benchmarking the Business of Agriculture’ Programme Value: £3,000,000 Programme Code: 204123 Review Date: 11/11/2014 Start Date: 18/11/2013 End Date: 31/08/2016 Summary of Programme Performance 2014 Year Programme Score A Risk Rating Medium Summary of progress and lessons learnt since last review This is the first annual review of the Benchmarking the Business of Agriculture project (BBA), a three year project commencing in 2013. The project has made good progress on the first component of the project – developing “Doing Business” style indicators for agriculture (DBA). The BBA team successfully completed the programme’s research and design phase, leading to the identification of indicator areas within nine topics, three more than originally planned. A further four topic areas have been identified for year two, based on the BBA team’s interactions with the ten pilot countries visited (access to information, livestock, gender, and environment). The team will integrate gender into 4 areas: land tenure, access to agricultural finance, water and farmer organisations. Environment will be mainstreamed within the seed, fertilizer, water and livestock topic areas. The first year pilot report is due to be published on 21 November 2014. This is slightly delayed owing to additional checks and peer review to ensure quality assurances. There were also some delays during the data collection phase as the team amended and updated their questionnaires. The BBA team have consolidated the lessons learnt from this first year (customised questionnaires, importance of desk based research ahead of time, liaising World Bank and supporting donors’ country offices), which will help improve timeliness of the second year report. Progress on the second component of the project – developing more outcome focused indicators that provide a deep dive (DD) assessment of the enabling environment in agriculture - has been mixed. The approach used for the DBA has proved to be unsuitable for these types of data. The team collected information and conducted surveys on these measures, but the comparability and robustness of the data was not deemed adequate for publication. During the second year, while focusing on scaling data collection for policy and regulatory indicators to 40 countries, the BBA team will develop a more coherent approach and alternative methodology to measure key variables that complement the DBA indicators. A set of options will be presented to the donors contributing to the mulitdonor trust fund for their consideration in February 2015. There have been concerns raised by some civil society groups that there has been insufficient communication about the project. Going into year two, the BBA team will roll out a stakeholder outreach strategy. Once the first year report has been published, the BBA team will have something tangible to communicate with. The BBA have also started actively engaging with country governments on the purpose and role of the indicators, and will continue doing so in year two. Summary of recommendations for the next year 1. Add access to information, livestock, gender and environment to the list of topic areas to cover in year two. 2. The DD indicators will be updated in March 2015, once a decision has been taken on how best to take this component forward. 1 A. Introduction and Context DevTracker Link to Business Case: DevTracker Link to Log frame: Business Case Logframe Outline of the programme The Department for International Development (DFID) is providing £3 million to the Benchmarking the Business of Agriculture project (BBA) over 3 years. The BBA was initiated in 2013, following a call by the G8 to “develop options for generating a Doing Business in Agriculture Index”. The BBA is housed in the World Bank Group, bringing together expertise from the Agriculture and Environmental Services (AES) department and the Global Indicators and Analysis department (GIA), with ten years of experience of implementing the Doing Business project. The BBA is funded through a multi-donor trust fund. Current representation includes USAID, DANIDA, the Bill and Melinda Gates Foundation, the Dutch Ministry of Foreign Affairs, and DFID. The overarching aim of the BBA is to incentivise policy-makers to streamline regulations and improve the enabling environment for agriculture. The project focuses on factors affecting the emergence and sustainability of agriculture-related businesses within the supply chain, necessary for a healthy and modern agriculture sector. By developing indicators that assess the enabling environment for agriculture and agribusiness, the project will enable policymakers to identify and prioritise policies and regulations that need to be in place to stimulate agricultural growth. The BBA has two main components: (i) Doing Business in Agriculture indicators and (ii) Deep-Dive assessments, looking more closely at the performance of the agriculture sector. (i) Doing Business in Agriculture indicators: these indicators focus on the laws and regulations that are the most important for agricultural productivity in countries around the world – developed and developing. The indicators will be consistent and comparable across economies, enabling benchmarking to take place. (ii) Deep Dives (DD): multi-country studies, which will add breadth to the range of indicators by going beyond the spectrum of the Doing Business type indicators, by examining a broader range of factors affecting agricultural productivity, market access, and the policy environment for agriculture. DDs will bring new benchmarks to the attention of policymakers and will provide a number of important new metrics to better enable policy makers to establish their country's position in relation to their neighbours and countries at a similar stage of agricultural development. These two components will work synergistically to develop indicators in six key areas of analysis: access to commercial seeds, access to agricultural finance, access to fertilisers, land, markets and transporting agricultural goods. These indicators will be used to track key laws and procedures affecting the ability of the commercial agricultural sector to deliver food at affordable prices, such as policies related to seed importation, land leases, SMEs’ access to finance and trade and customs policies affecting the movement of goods across the borders. Gender considerations will be built alongside these six areas. The BBA indicators will be carried out in three years, starting with a pilot phase of data collection in 10 countries in 2013, scaling up to 80 countries in Year 3. The Deep Dives indicators will be collected and reports prepared for nine topics over a course of three years. The project supports DFID’s new strategic framework for economic development, specifically pillar 2: “supporting the enabling environment for private sector growth”. It will help bring transparency to the sector, while also supporting governments to track the effectiveness of their agriculture based approaches and programmes. 2 B: PERFORMANCE AND CONCLUSIONS Annual outcome assessment The overarching outcome of the BBA is that it becomes a key policy tool for policymakers leading to indicator-informed regulatory reform. Two out of the four outcome level indicators have milestones for each of the three years of the pilot project. For the remaining two indicators, results are only expected in the final year. On the first indicator (countries' understanding of impact of agribusiness enabling environment is enhanced by dissemination of BBA reports), the BBA team launched their website (http://bba.worldbank.org/ transitioning to http://eba.worldbank.org) in December 2013. It has had a greater number of hits than the target in the logframe (4,270 compared to 3,000). No media clips have been uploaded (target of 10 in 2014). There has been a shift in outreach to be more inclusive and interactive, and less on media clips. The milestone for June 2015 will be revised to reflect this change in focus. On the second indicator (number of countries actively using the BBA indicators to inform policy improvements), the BBA team actively engaged in discussions on the ability of the indicators to drive reform with four country governments (Rwanda, Spain, Guatemala and Uganda). The original target was two. Additional countries have since expressed an interest in having this more in-depth discussion. Despite positive progress in these areas, there are still some groups (civil society, wider, government stakeholders, and donor country office staff) that are unaware about the purpose and vision of the BBA project. The BBA team have taken steps to address these concerns in two ways: First, by developing a stakeholder outreach strategy, which looks to engage and involve both civil society and private sector players on the role of the BBA. This has been slightly delayed due to the team wanting to wait until the data collection exercise had finished. This delay has been interpreted as secrecy by some, underscoring the importance of active dialogue throughout the process. The second initiative the BBA team is considering is a partnership with an African institution to help improve awareness, use and application of the product. This partnership would also help inform how best to engage policy makers and provide an additional forum for discussion across the region. If successful, this type of partnership could be rolled out in other regions. One issue that has been flagged to the BBA team is the difficulty of translating Benchmarking the Business of Agriculture into other languages. The project’s name has therefore been changed to “Enabling the Business of Agriculture” (EBA). For the purposes of this review, BBA will be used to refer to the project. All future documentation will refer to EBA. Overall output score and description The overall output score after the first year of the project is A: outputs met expectations. There has been significant progress in some areas and delays in others, partly due to issues that were not considered at the time the business case was written. On the first output, the BBA has moderately exceeded expectations. They have looked at an additional three topics – one of which was brought forward from year two, and organised two separate events to discuss the BBA (FAO and Seep Community), one more than targeted. Interviews with donors, contributing into the trust fund, civil society organisations and one of the pilot countries, suggest that there is satisfaction on the technical capacity of the BBA team to undertake this work. Data collection has proved challenging, and the team have responded by ensuring they have the correct skill set in the team, ensuring technical rigour across the piece. The pilot report is slightly delayed to ensure the findings could be internally crossed checked and peer reviewed before publication. On the second output, progress is moderately under expectations. The methodology used to collect data under the first output is not suitable for these types of data. Whereas this kind of data was collected during the project’s first year, it could not be gathered and presented in a reliable and robust manner, affecting data quality, precluding comparability of the information and limiting scalability to a larger number of countries. Based on the pilot year experience, the BBA team is working on developing an approach and methodology to collect and integrate this category of information. A set of costed options will presented for consideration by the donors of the multi-donor trust fund in February 2015. 3 Key lessons There are six main lessons learnt from the first year of the project: Questionnaires need to be tailored to different contributors: the master questionnaire for each topic area has been customised for each contributor type (e.g. private companies, aggregators, producer organisations, lawyers). This has reduced the time taken to do interviews and ensured the most relevant information is collected. Heterogeneity of farming makes benchmarking difficult: not all countries farm the same crops. Similarly, at difficult stages of development, different farming practices take place. Finding one master questionnaire or even one uniform set of indicators has therefore proved challenging. An omission of livestock specific questions has led the team to include this as a separate topic area in year two. Engagement is key for data collection: engagement of target country governments to garner interest and support for the program, in many cases, generated key contacts, facilitated data collection and established a foundation for ongoing interaction. World Bank country offices helped provide some of these contacts. The BBA team has also been encouraged to use donor country offices for additional contacts and support. Data collection can be started before country visits: Whereas data are collected from key incountry contributors using specially designed questionnaires, the project has learned of the importance of gathering and organising background data for each of the target countries and topic areas to make data collection more effective. This has been incorporated as a fundamental part of the process of data collection for year two. A focus on key metrics allows the project to scale-up: given the volume and breadth of the data that can be gathered within each topic area, a key lesson was the importance of selecting, collecting, organising and refining data in a manner conducive to the development of indicators that are focused, scalable to a global level and actionable. A clear articulation of the BBA vision is needed for outreach: while the BBA team has actively organised conferences and seminars to talk about the BBA project, some stakeholders and governments in the pilot countries still lack clarity on what the project is ultimately trying to achieve. Articulating a clear theory of change of the BBA to support engagement will be key when implementing the outreach strategy. Key actions Based on the findings of the BBA team during the first year, there are three action points: An additional four topic areas have been added to the data collection exercise for year two: access to information, livestock, gender and environment. Gender issues will be mainstreamed into 4 areas: land tenure, access to agricultural finance, water and farmer organizations. Sustainability will be mainstreamed within the seed, fertilizer, water and livestock topic areas. After data collection and analysis, the ideal reporting format will be determined for these indicators. For the DD component of the project, the BBA team will continue working on an alternative methodology, collecting data where possible during the second year. Options will be presented to donors on the way forward in February 2015. Has the logframe been updated since the last review? The milestone for output 1, indicator 1 in June 2015 has been updated to reflect the addition of four further topic areas in year two. The indicators for the second output will be updated in March 2015, following a discussion on options with the BBA team. 4 C: DETAILED OUTPUT SCORING Output Title Development and roll-out of Doing Business in Agriculture methodology Output number per LF 1 Output Score A+ Risk: Medium Impact weighting (%): 50 Risk revised since last AR? N/A Impact weighting % revised since last AR? No Indicator(s) Milestones Progress 1.1 Number of DBA indicators developed 6 indicators: (1) Access to Finance, (2-3) Access to Inputs (seeds and fertilizer) (4) Access to secure property rights on land, (5) Access to markets, (6) Access to transport 1.2 Number of countries in which DBA is rolled out 1.3 Number of DBA reports produced. 10 Pilot countries Data collected for all of the 6 topic areas with suggested indicators provided. Initial data for an additional three topics collected: contract farming; rural electricity, and ICT 10 pilot countries reported on 1.4 Number of workshops, seminars, conferences organised or coorganised At least 1 event Pilot report Pilot report circulated to donors but yet to be made public at the time of this review Two events organised: seminar at FAO & with SEEP Key Points By the end of the first year, the BBA team successfully completed the programme’s research and design phase. They covered the six topics covered in the business case (access to finance, access to seeds, access to fertilisers, access to secure property rights on land, access to markets, and access to transport). In addition to these six, the team looked into “access to information” and “contract farming”, as well as rural electrification, which was brought forward from year two. The total number of topic areas tested was nine, three more than originally planned for. Based on the findings in year one, a light touch approach to access to information technology and rural electrification will be applied in year two. The BBA has drawn on the expertise housed in the World Bank, compiling a team with the relevant skills for the different topics areas and knowledge of indicator development. The project has been held up by World Bank management as a good example of integrated working between the IFC and the World Bank, bringing together human and knowledge resources across two departments - the Agriculture Global Practice and the Global Indicators Group. During the first year of piloting, the team noted the relative absence of information on livestock farming. This became obvious in their interviews with a range of private sector and civil society organisations, which had specific points to cover on the regulatory environment as it related to livestock. Similarly, there were a number of issues raised under the theme of gender and environment during their interviews, suggesting that these two themes would merit their own topic area as well as being mainstreamed into other relevant topic areas. At the time of this review, the pilot report has been circulated internally to the World Bank for peer review, and to the donors funding the project. An abridged summary of the report and key messages has been circulated and discussed with the FAO and with the SEEP community – bringing the number of seminars organised up to two from one in the original results framework. While these types of seminars have been useful, more could be done to widen the project’s outreach. Feedback from reviewers has been incorporated and is part of the final report, which is due to be published on the BBA website on 21 November 2014. Summary of responses to issues raised in previous annual reviews (where relevant) Not applicable Recommendations 1. Add access to information, livestock, gender and environment to the list of topic areas to cover in year two. 5 Output Title Development of Deep Dive multi-country studies Output number per LF 2 Output Score B Risk: Medium Impact weighting (%): 50 Risk revised since last AR? N/A Impact weighting % revised since last AR? No Indicator(s) Milestones Progress 2.1 Number of DD indicators developed 6 indicators: (1) Access to Finance, (2-3) Access to Inputs (seeds and fertilizer) (4) Access to secure property rights on land, (5) Access to markets, (6) Access to transport 2.2 Number of DD reports produced Pilot report Market metric developed in 6 topic areas: (1) Access to Finance, (2-3) Access to Inputs (seeds and fertilizer) (4) Access to secure property rights on land, (5) Access to markets, (6) Access to transport. No separate report. The data under the deep dives are neither statistically robust nor comparable, and therefore not in a condition to be used or published. Some of the findings were wrapped up in the DBA report. Key Points During the first year of data collection the BBA team collected data and information relevant for the Deep Dive (DD) component of the project. They collected this information using a similar approach as the “Doing Business” style indicators, using tailored surveys targeted as selected organisations, including private sector entities, civil society organisations, and government officials. They also looked at government collected data on indicators such as road quality. This type of methodology has proved to be inappropriate for data aimed at drawing measurements at the level of practices, implementation, outcomes and/or market conditions. Verification based on a small sample size of survey respondents has not presented robust results that can be compared across countries. Furthermore, country level data were either not available or not comparable owing to the application of different definitions. The BBA team has therefore revisited their approach to the DD component of the project. The team has been requested to develop costed options on how the DDs can be taken forward. These options will be presented to the contributors of the multidonor trust fund for their consideration in February 2015. This will help inform a final selection of this category of data, in close connection with the policy and regulatory indicators (the DBA indicators) under development. Despite these setbacks, the project remains committed to developing indicators on more outcome focused areas, which they are now terming “market metrics”. They have used the DD information collected during year one in two ways: (i) (ii) to provide additional context in the pilot report covering the “Doing Business” style indicators; and to produce a report on potential DD indicators and data. This latter report has not be circulated or made public due to data quality concerns. Recommendations The logframe will be updated in March 2015, once a decision has been taken on how best to take this component forward. 6 D: VALUE FOR MONEY & FINANCIAL PERFORMANCE Key cost drivers and performance Two drivers of vfm were identified in the BBA business case: (i) the design and development of indicators (economic efficiency) and (ii) the take up and impact of DBA and DD indicators in the decision making of policymakers in developing countries (economic effectiveness). The project continues to represent vfm in relation to economic efficiency. It is too early to assess the vfm of the BBA project’s economic effectiveness but early indications suggests this is on track. VfM performance compared to the original VfM proposition in the business case Economic efficiency The business case identified three indicators to assess the value achieved in input purchasing (economy) and how these are converted to outputs (efficiency): Proportion of total costs allocated to value-adding operations: operations (research, indicator development, data collection) are the BBA’s key value-added. Over the life of the project (3 years), the cost of management, consultants, staff and travel and accommodation needed for field work will constitute 78 percent of total costs. The project has spent approximately one third of the allocated budget for operations in year one. Desk based research should help ensure the project keeps in budget when additional countries are added in year two and three. Cost per report produced: an assessment of the cost per report will need to be amended following the changes to the DD component of the project. Communication costs: 5 percent of the BBA’s budget has been allocated to communication activities. The website and seminars have been low cost items, meaning the BBA project has underspent on communications in the first year. This is expected to change in year two when the outreach strategy is implemented. Economic effectiveness Measures to track BBA’s effectiveness include: Instances where BBA research and reports have been used by countries to inform policy improvements. Evidence of wider BBA uptake and use of credible methodology, measured by media citations, website visitors, journal and article references. Number of regulatory reforms undertaken using the BBA indicators. Process of agreeing to reform, which is consultative and time and cost-effective. Wider impact of policy changes that are assessed in a time and cost-effective manner. The overall effectiveness of the project is expected to increase over time and crucially depends on the quality of the outputs from the project and outreach. The rigorous assessment of the data applied by the BBA team and the peer reviewers helps ensure the impact of the project is realised. Assessment of whether the programme continues to represent value for money The BBA continues to represent value for money. Quality of financial management The BBA is a World Bank Multi Donor Trust Fund. DFID’s £500,000 contribution for this financial year has been disbursed as per the Administrative Arrangement. The next disbursement of £500,000 is due by 31 March 2015. There is no expectation that the current approved budget or forecasting profile will change over next financial year. The World Bank produces a single annual audit, released 6 months following the end of the Bank’s fiscal year (due 31/12/2014). The narrative financial report was received by DFID in October 2014. This included a detailed breakdown of donor contributions, disbursements and undisbursed commitments. Date of last narrative financial report Date of last audited annual statement September 2014 n/a 7 E: RISK Overall risk rating: Medium What are the risks and how these will be managed? Two main types of risks were highlighted in the business case: (i) the purpose and methodology of BBA is not well understood; and (ii) the programme cannot achieve buy-in among policymakers and key users. The risks, mitigation strategies and updates on any progress made and changes in context are provided in the table below. Risk identified in business case Risk rating Confusion over what the indicators do and don’t measure. Medium DBA and DD are not well integrated and the programme narrowly focuses on legal and regulatory indicators. High Brand/position DBA and DD as one core product with two separate but complementary components working in a synergistic way. Significant variations between the regulatory frameworks for different agricultural commodities limit the comparability of BBA indicators. Indicators produced are not considered to be rigorous and evidence based. Medium Indicators will use a standardised case study to allow comparison across different countries. LowMed Countries selected are not aligned to programme objectives. LowMed Lack of government buy-in Medium Programme activities do not lead to regulatory changes. LowMed Pressure over DB and country rankings lead to pushback on BBA. Unintended consequences Med Governments narrowly target their reform efforts to trigger the time and motion indicators only. Medium A broad group of stakeholders (including researchers, target users, subject-matter experts) should be consulted and their advice should inform indicator selection and subsequent refinements. WB will consult donors on the country selection process and the intention is to select a geographically diverse set of countries at different stages of agricultural growth to allow for subcomparisons. Take-up and Buy-In Governments of countries in which BBA will be rolled out must be informed and consulted. BBA should continuously assess opportunities to affect changes in the regulatory environment related to the project’s interventions. BBA should carefully consider pros and cons before proceeding with country rankings. The programme will devise a way to model the expected policy responses from the indicators to ensure against negative outcomes. BBA should encourage a broad reform discussion as opposed to narrow indicator-focussed reforms. Medium How will risk be managed? Methodology BBA to continually communicate the range and limits of the data. 8 Annual Review Update Outreach strategy developed and potential partnership with an African institution being developed Ensure a common theoretical framework for the DBA and DD indicators in one joint report. Risk has been increased from medium to high. The standardized case scenario will be based on statistics of the most traded product, the main agricultural production area and the main trading partner at a regional and international level. Mitigation measures are taking place, including the development of technical notes summarising the evidence on the topic areas and broader agriculture reform. Mitigation measures are taking place. Mitigation measures are taking place. BBA team developing a framework to assist countries in their thinking on agricultural transition Mitigation measures are taking place. Mitigation measures are taking place. Outreach strategy with private sector is being developed. Further engagement with governments as the indicators develop will be needed. The process of agreeing to policy changes is inclusive and consultative at countrylevel. Programme is not sufficiently proactive to engage stakeholders. Medium Medium The programme should pay attention to not only encouraging policy reforms, but how they have been achieved. Specific actions including a strategic outreach plan should be a central component of the programme. This is an element of the DD component of the project. More engagement is needed during the second year to address some concerns raised by civil society. Outstanding actions from risk assessment The risks to the project’s ability to deliver results remain relevant. The team have put in place a number of mitigation measures in line with the original risk assessment outlined in the business case. On the first set of risks, another will be added: “Insufficient resources to take forward the DD indicators” This is a medium to high risk. The current mitigation measure is a clear articulation by the BBA team of their options available to develop the DD indicators under the current budget, and what more is required to develop them in more detail. The budget cuts and on-going restructuring within the World Bank Group add a level of challenge in some of the project’s processes, but which is expected to be addressed as the project moves forward. On the second set of risks, additional action is needed during the second year of the project to ensure buy-in, given some of the concerns of civil society. The implementation of the outreach plan currently under development should alleviate some of the concerns. F: COMMERCIAL CONSIDERATIONS Delivery against planned timeframe The BBA team have made a promising start and have gathered a rich set of data and information on the relevant topic areas. It has, however, taken more time that originally anticipated, collecting the data and organising country level interviews with relevant stakeholders. The diversity of the responses and data has also meant quality assurance has taken longer. This has led to a delay of the first year report by a few months. As the team embark on data collection in the second year for 40 countries (the original 10 plus an additional 30), an initial desk based data collection will take place before country visits. This research will use the questionnaires and surveys piloted during the first year. Country visits will then take place to triangulate some of the data and fill gaps where information is not readily available from outside the country. Performance of partnerships The multidonor trust fund has met face-to-face twice since its inception. In between these meetings, there have been regular conference calls with the donors and the BBA team. During the early stages of the project, the phone calls were more regular, with the donors sometimes organising separate phone calls to align thoughts before feeding into the BBA team. On 9 December 2013, the BBA team hired a programme manager. This has greatly enhanced the ability of the team to communicate with donors on progress and request steers on strategic direction. While DFID has participated in these meetings and calls, staff changes (3 over the course of the first year) have meant continuity has been fragmented. Asset monitoring and control Not applicable G: CONDITIONALITY It was not deemed relevant to use the partnership principles for management and monitoring when the programme was approved. 9 H: MONITORING & EVALUATION Evidence and evaluation The evidence and context in which this project was devised remains relevant. Sustained economic growth, combined with strong domestic and global demand for food and agricultural commodities, offers unprecedented opportunities to transform agriculture in a way that creates jobs, income and opportunities for agribusinesses and the large smallholder base. Relatively low levels of investment in agriculture in SSA highlight the need to improve our understanding of enablers and barriers to the promotion of agriculture as a business. The BBA fills this gap by developing comparative indicators and actionable information for policy makers and the private sector to assess the ease of doing business in agriculture, across different countries and over time. One area the project does not capture is the issue of governance and the political economy around agriculture. Ad hoc policy reforms and vested interests can severely impact the capacity of the agriculture sector, both as a driver of growth, and as a mechanism to bring people out of poverty. DFID has spoken to the BBA team about whether these types of issues could be covered in the existing project, using the data and methodologies available to them. Finding comparable and objective indicators in this space is difficult and something the team has looked into, but not found any hard data as yet. A mid-term evaluation is planned following the publication of the second year report. To allow sufficient time for the results of the report to be internalised, this evaluation will take place around September 2015. It will focus on the ability of the BBA to influence reform of the enabling environment for agribusiness. Monitoring progress throughout the review period The BBA team monitors progress against internal milestones related to data collection, questionnaire development and reports. In addtion, they prepare a stocktake of progress for presentation to the donor group every 6-8 weeks. The team have been very responsive to requests for information from DFID and have actively contributed to this annual review, providing useful insights and reflections on the past year. They have started working on an agricultural transformation framework and the relationship between the ratio of agriculture to agribusiness within different economies. This could be an effective tool that governments can use for looking at long term impact in different countries. The BBA team has also started developing a baseline with cost measures. While a critical mass of information will need to be gathered across a number of years before this progress can be tracked, this is a useful set of data to start tracking in the early stages of the project and will help feed into the evaluation. For this annual review, all of the donors contributing to the project were consulted and their views on the project gathered. The donor group has been working effectively, consulting on a number of issues and actively feeding into the project. Views were also gathered from civil society representatives based in the UK. 10