National content met, community content missed

How a project reports seventy per cent local employment while the affected parishes get nothing, and the disaggregation that exposes it.

Olule Solomon8 min read

A project can report seventy per cent Ugandan employment and be the single largest source of grievance in every district it crosses. Both things are usually true at once, and they are not in tension. The workforce is Ugandan — recruited from Kampala, or carried over from the contractor's previous project — while the parishes losing land to the corridor supply almost nobody.

National content and community content are different obligations with different failure modes. Conflating them produces exactly this outcome: the aggregate target comfortably met, and the people bearing the disruption receiving none of the benefit.

Disaggregation is the whole fix

Report employment by district and by affected parish, not by nationality. Set the community target separately from the national one. A single aggregate figure is precisely the instrument that allows the failure to persist while being reported as a success — and it will keep doing so for as long as it is the only number anyone asks for.

Define "community" before recruitment starts

Which parishes count, and what document establishes residence. Agreeing this after a dispute has arisen guarantees a definition that ratifies whatever already happened, and everyone who lost out will read it that way.

Hiring at the gate is unrecordable and captured

Recruitment conducted each morning at the site entrance produces real local employment and no auditable record of it. Worse, it is reliably captured by whoever controls the gate — a foreman, a local broker, sometimes a payment — which converts a benefit into a grievance about who was chosen.

Advertise locally, screen against stated criteria, record the decision. The additional work is a morning's administration and it is the difference between a target you can evidence and a number you assert.

Fronting: the JV that satisfies the paperwork

Where a joint venture with a Ugandan firm is required, the requirement is routinely met with an arrangement in which the local partner performs no work and carries no risk. A document check cannot detect this. A substance test can: what scope does the local partner actually deliver, what staff does it employ on the project, and what does it stand to lose if the work is defective?

A plan that requires a JV without a substance test is requiring a certificate.[1]

Local capacity is something you build

"Local suppliers cannot meet our standards" is the standing explanation for unmet procurement targets, and it is often an accurate description of the present. It becomes an excuse when nothing in the plan is designed to change it.

Prequalification support, feedback to unsuccessful bidders, contract packages sized for a small firm — and above all, payment terms a small supplier can survive. A contract that says thirty days and pays at a hundred and twenty does not merely miss its target; it removes local capacity from the market for the next project as well.

CSR is not compensation

Compensation and resettlement entitlements are obligations owed to identified people. Corporate social responsibility is discretionary spending for the community at large. The plan should state explicitly that one may never be counted against the other.

The failure this prevents is real and recurrent: a borehole delivered as CSR, later set against a household's compensation entitlement. That extinguishes a legal obligation with a gift the household never agreed to accept in its place.

Numbers that reconcile to something

Content figures are usually compiled by the party being assessed, from sources nobody outside that party can see, and then reported to an employer and a lender with no means of testing them. State in the plan which underlying registers the figures derive from — payroll for employment, accounts payable for procurement — and who may audit them. A number that reconciles to payroll is a fact; a number that reconciles to another spreadsheet is a claim.

Sources

  1. [1]Public Procurement and Disposal of Public Assets Act, 2003 — Uganda Legal Information Institute (ULII), 2003.

Olule Solomon

Lead Consultant, ValueSpace

Olule Solomon is Lead Consultant at ValueSpace, where he works on land acquisition and resettlement systems for donor-financed infrastructure in East Africa. He writes about the practical gap between what the safeguard standards require and what a project can actually evidence at completion audit.

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