Four independent evaluators awarded points to the projects and programs of non-governmental organizations as part of the Public Competition "Let's Develop Cultural Habits", while the Committee for the Distribution of Funds was only involved in administrative work in that part, "News" from the Ministry of Culture reported.
"The submission of data as well as the engagement of independent evaluators is treated as confidential, as stated in the act of the Ministry of Public Administration (MJU). This year, four independent evaluators were hired," the Ministry of Culture answered when asked about the names of the evaluators.
At the end of each year, the MJU appoints independent evaluators for the following year. "Vijesti" was unofficially told by this department that they only choose evaluators, and that the ministries later hire them themselves, without their consultation, and therefore they do not have information about their further engagement and do not know which four made decisions at the competition of the Ministry of Culture. An updated list of independent evaluators for 2020 was published on the MJU website in February. The director of the Directorate for Cultural Heritage of the Ministry of Culture, Dobrila Vlahović, is also on that list. Vlahović was also a member of the Ministry's commission for this competition.
In addition to her, independent evaluators are Aleksandar Čampar, Aida Spahić, Andrea Popović, Boban Tomić, Damir Laličić, Dragan Damjanović, Dragana Damjanović, Dženita Hukić, Goran Prebiračević, Kana Tomašević, Krsto Vukadinović, Maja Subotić Medenica, Marija Milović, Marko Rakić, Mirko Rajković, Miroslav Đukić, Nebojša Jovović, Radule Dragović, Sanja Stanić, Stoja Popadić, Tatjana Mališić Delević, Vesna Gajević. , Zoran Poleksić and Željka Stamentović. Due to the confidentiality of the data, he does not know which of them were the evaluators in this competition.
All independent evaluators apply for that position with a submitted curriculum vitae and area of interest, on the basis of which the ministries later hire them, they told "Vijesti" from MJU.
In the "Guidelines for independent evaluators of projects and programs of non-governmental organizations registered for competitions of state administration bodies", MJU, which "Vijesti" had access to, nowhere does it say that the evaluators and their engagement are confidential in the context of secrecy. In the section "Scoring projects and programs according to the criteria" it is pointed out that "selected independent evaluators are required to sign a declaration of confidentiality, impartiality and non-existence of conflicts of interest in relation to the projects and programs they will evaluate before the evaluation". The statement is signed after reviewing the list of applications for NGO projects and programs.
"Confidentiality - the evaluator must ensure the confidentiality of the data he received in the projects, that is, programs, and he will be expected to sign a declaration of confidentiality before starting work on scoring," the Guidelines state. On the other hand, the Commission for the distribution of funds within the competition is made up of representatives of the body that conducts the Public Competition, in this case the Ministry of Culture and non-governmental organizations. The commission in this competition consisted of the president Marija Mrvaljević and members Milica Martić, Azra Hrapović, Dobrila Vlahović, who is also on the list of independent auditors for 2020.
"We emphasize that the members of the Commission provide administrative and technical support when submitting projects/programs, and independent evaluators decide on the scoring of projects," told "Vijesti" from the Ministry of Culture. They explain that after the committee has checked the received documentation, the projects are scored by independent evaluators, and later the committee "prepares a decision on the distribution of funds after the submitted score lists drawn up by them". At this year's competition, among the rejected projects are some of the leaders of the Montenegrin cultural scene or local art scenes.
"We note that, in accordance with the proposals and conditions of the competition, the quality of the offered projects/programs was first of all evaluated on their side," the Ministry of Culture explains and says that scoring is done on the basis of the Manual for the Application of the Legal Framework for Financing Projects/Programs of Non-Governmental Organizations from Public Sources, which was prepared by the National Office for Cooperation with NGOs - Ministry of Public Administration.
In their address to "Vijesti", several NGOs expressed doubts about the criteria and selection of non-governmental organizations that were supported in the competition, calling into question the work of the commission, independent evaluators, as well as the activities of other non-governmental organizations. The conflict of interest of Azra Hrapović, who was proposed by some of the NGOs that received funds, as well as "Đakomo Adriatic", whose founders she was until 2014, as she told "Vijesta", after which she was only "occasionally engaged" in the work of that NGO, was also questioned.
"Ms. Azra Hrapović, as a representative of an NGO and a member of the Commission, did not participate in the administrative-technical procedure carried out by the Commission, both for her project and for the projects/programs submitted by the NGOs that proposed her, which is stated in the Decision on the establishment of the commission for the distribution of funds for the financing of projects/programs of non-governmental organizations for 2020, as well as in the Decision on the distribution of funds to non-governmental organizations for projects in the fields of art and culture. In the context of the above, the legal procedure was fully complied with," the Ministry of Culture replied.
The president of the commission, Marija Mrvaljević, whom "Vijesti" contacted, also pointed out that there is no conflict of interest in this case.
"The NGO project 'Đakomo Adriatic' was supported in the Competition in accordance with the points obtained by independent evaluators, because it had previously fulfilled all the administrative and technical conditions prescribed by the Competition. Of course, there is no conflict of interest, because the legal provision for her (Hrapović's) exemption was complied with," said Mrvaljević.
When "Vijesti" asked the Ministry of Culture whether it is possible to expect changes to the Decision on financing NGO projects in the fields of culture and art, they said that there is no reason for that.
"Given that all legal provisions and administrative-technical procedures have been followed, which include: publication of the Public Tender, publication of the list of NGOs that did not submit a proper and complete application, making a decision on the distribution of NGO funds for projects in the field of art and culture, publication of the ranking list of projects/programs based on the number of points determined by independent evaluators, and publication of a tabular review of NGOs whose applications did not meet the administrative requirements from the Public Tender, there is no valid reason to change this decision".
Hrapović: I exempted myself from the NGO, not everyone can get money
Among the 20 programs that received financial support from the Ministry of Culture is the non-governmental organization "Đakomo Adriatic".
One of the founders of this NGO is Azra Hrapović, who was also a member of the Commission of the Ministry of Culture for the distribution of funds for financing programs of non-governmental organizations.
At the tender, "Đakomo Adriatic" received support of less than 10.000 euros for the program "Cultural and artistic needs in Montenegro", which it will do with the partner NGO "Centar Sjevera".
Hrapović told "Vijesta" that she exempted herself from that process, but that she is no longer among the founders of this NGO.
"When checking the technical documentation, I asked for my exemption, as prescribed by law, for which there is evidence. I also note that as a member of the Commission I neither vote nor support projects, but as a member of an NGO I monitor the transparency of the process and participate in the work of the Commission", said Hrapović. When asked about her candidacy, she said that she was chosen based on a public invitation from the two candidates registered "given the number of supports that I received and which were valid".
According to the document on the website of the Ministry of Culture, Hrapović received the support of 14 valid applications and another 19 invalid ones, and her opponent four invalid ones. Among the NGOs that supported her candidacy are at least five more that eventually received funding from this competition.
The representative of the NGO Nova Center for Feminist Culture Nataša Nelević, who previously complained about the results of the Ministry's competition, pointed this out to "Vijesti".
Nelević assessed that on the list of supported programs of the Ministry of Culture, "there are several organizations, without any significance in culture, that supported Azra Hrapović's candidacy for the position of a member of the Commission, probably so that she would return it to them in this way".
Hrapovic denied it.
"The Commission's role is to check the received documentation, as well as the completeness of the application, because incomplete applications are not considered. Every further process, which is scoring, goes to independent evaluators who are competent, because they have already been on the list of the Ministry of Public Administration with their evidence. Which means that until the final list sent by the independent evaluators, I was not aware of the results until the moment when the Commission sent the invitation. Those who work in associations and NGOs should really know this," said Hrapović, adding that they should accept the fact that out of 200 or more applications, not all of them can be funded, but only a certain number.
ASK: We will initiate administrative proceedings
When asked whether Azra Hrapović was in a conflict of interest because she was a member of the Commission, but also the founder of an award-winning NGO, the Agency for the Prevention of Corruption told "Vijesta" that the matter will be "treated as a report from the field of conflict of interest, they will initiate administrative proceedings, establish the factual situation and make an appropriate decision".
By looking at the earlier announcements of the Ministry of Health, headed by Kenan Hrapović, but also in the database of the open data portal, it can be seen that the NGO "Đakomo Adriatic" was allocated 6.036 euros from that department two years ago for the program "Prevention of drug abuse in the community with a special focus on the education system".
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