1. Part III: Assessment of the Code of
Conduct for Ethiopian NGOs
1 Introduction
Relevance
Is the code of conduct relevant to the CSO context in Ethiopia?
for the legislative /mandatory regulation framework for CSOs in Ethiopia?
for the profile and membership of CCRDA?
the number and profile of organizations intended to be covered?
Comprehensiveness
Does the code of conduct have all the relevant sections?
general section indicative of organizational aspirations;
a detailed section setting down specific principles, rules and policies which members of the
organization are expected to adhere to; and,
a third section dealing with the management of the code of conduct including structures,
procedures and standards for the implementation and enforcement of the substantive
provisions.
Is the level of detail under each of these major sections appropriate for the nature and purpose of
the code?
The Code of Conduct for NGOs in Ethiopia (March 1999) has three sections: a background, standards
of conduct and code observance. In terms of content, the first section could be considered the form
while the latter two constitute the body of the Code. The first section covers the following items: a
brief introductory section focusing on the process of code development, a preamble with a
paragraph on the need for the Code as well as statements on its constitutional basis and a statement
on form, citation and definition of four key terms/references, purposes of the Code, and a generic
statement of NGO mission. The second section presents statements of commitment under eleven
principles, namely: people centered, fairness and equality, moral and ethical integrity, transparency
and accountability, good governance, independence, communication and collaboration, gender
equality, environmental consciousness, sustainability, and impact. The last section of the Code
provides for the establishment, composition and functions of the General Assembly and the NGO
Code Adherence Committee to ensure observance of the Code as well as complaints procedures, and
a provision on revision.

2. The first issue that needs to be considered to determine the comprehensiveness of the code is
whether the code of conduct has incorporated all the relevant sections. In general terms, three
sections are expected, namely: a general section indicative of organizational aspirations; a detailed
section setting down specific principles, rules and policies which members are expected to adhere
to; and, a section dealing with the management of the code of conduct including structures,
procedures and standards for the implementation and enforcement of the substantive provisions.
The NGO Code of Conduct does contain separate sections for specific standards as well as
implementation and enforcement. While not stated in a separate section, the contents of the
background section and the eleven headings for the standards of conduct cumulatively constitute a
general statement of organizational aspirations. In the following sections, we will assess whether the
level of detail under each of these major sections appropriate for the nature and purpose of the
Code.
2 General Section
The general section of a code of conduct is expected to cover four major items: the rationale and
objectives of the code; its scope of application; the underlying value framework, and definition of
terms.
The NGO Code of Conduct refers to its rationale in the introduction, preamble and statement of
purpose. The last paragraph of the introduction relates how the Code has introduced for the first
time standards for previously unregulated activities and is expected to encourage more effective and
efficient ways of working, improve the partnership between the NGO sector, the government and the
private sector, and ultimately contribute to an enabling environment for all sectors and to the
sustainable development of Ethiopia and its people. The preamble to the Code similarly highlights the
need for the NGO sector to devise and implement a Code of Conduct that reflects its own core values,
ensures the observance of its norms, and leads to effective and efficient co-ordination and collaboration
with the Government, the general public and other partners. Finally, the provision on ‘Purpose of the
Code’ specifically identifies its objectives as ensuring and improving transparency and accountability,
quality of service provision, communication, and performance in the sector. As such, the general
section of the Code of Conduct for Ethiopian NGOs does provide for the rationale and objectives of
the Code in sufficient detail.
The scope of application for the provisions of the Code is stated under article 10 of the last section.
This provision stipulates that the Code is applicable to NGOs operating in Ethiopia and having signed
the document as well as their officials and staff. The provision also refers to the definition of NGOs
within its provisions, i.e. item one of the definitions provision. The Code also provides for a brief but
sufficient conceptual and descriptive explanation of elements of the NGO definition. As such, the
Code of Conduct does cover its scope of application.
The underlying value framework of a code of conduct consists in the vision, statement of mission,
guiding principles, and values shared among its signatories. The Code of Conduct for Ethiopian NGOs
clearly states its mission in the last provision of the general part entitled ‘NGO Mission’. The provision
also identifies the strategies to be employed to realize the stated mission as empowerment and
partnership with stakeholders. Though not stated as such, the headings of provisions outlining the
standards of conduct obviously constitute the basic and operational guidelines of the Code. Some of
these heading, such as independence, integrity and fairness, similarly represent values. However, the
Code does not make any clear reference to the shared vision of signatories, presents its underlying

3. value framework (guiding principles, operational principles, and values) in a somewhat haphazard
manner, and is lacking in comprehensiveness and consistency. For instance, ‘good governance’ is
presented on the same footing as its key elements, i.e. ‘transparency’ and ‘accountability’, and
operational standards such as sustainability and impact have made the list along with the core
values.
Finally, the definition of important or repeatedly used terms has been provided in the background
section of the Code. The terms defined in this section are code of conduct, NGOs, signatories and
civil society. However, other equally important terms have not been defined. These include, inter
alia: good governance, accountability, transparency, integrity and independence. Defining these
terms might have precluded some of the confusion in the ‘Standards of Conduct’ section.
2.1 Rationale and Objectives
In assessing whether the general and specific objectives properly designed and presented, the key
indicators identified in the previous section refer to a clear statement of objectives, and relevance to
the problem to be addressed. The provision on ‘Purpose of the Code’ identifies its objectives as:
ensuring transparency and accountability in the operation of NGOs by voluntary self-
regulation;
improving the quality of services provided by NGOs by helping NGOs to adopt high standards
of conduct and to devise efficient decision-making processes;
improving communication between the NGO community and the various stake holders.
improving the performance of the NGO community by encouraging the exchange of
experiences among its members and learning from proven best practices.
The rationale for developing the Code of Conduct for Ethiopian NGOs is described in terms of
anticipated benefits rather than problems encountered. However, the first two paragraphs of the
Code describe changing contexts demanded changes in the role of NGOs. The Code first elaborates
how the droughts of 1973-74 and 1984-85, which directed the focus of NGOs to relief, were replaced
by rehabilitation and development as the major development challenges in Ethiopia. Then it states:
“This change from emergency relief to sustainable development is of far-reaching
significance to Ethiopia and needs to be handled with care, transparency and
accountability. There is also an increasing involvement of NGOs in advocacy, in human
rights and civic education. As NGOs have emerged as important development partners,
they need to inform what they stand for, their policies, achievements and what they
plan to do in the future”.
Thus, the problem the Code sought to address relates to clarifying and aligning the role of NGOs to
the evolving development challenges in the country. This conclusion is also supported by the focus
of the code development process on the role of civil society.
The key question then is whether and to what extent the objectives identified in the Code are
relevant to this problem. In this light, the identification of objectives with focus on ensuring and
improving transparency and accountability, quality of service provision, communication, and

4. performance in the sector had been appropriate. By the same token, more recent changes in the
operational context for the civil society sector, especially in the regulatory framework, demands an
overhaul of the self-regulation system designed in 1998.
2.2 Scope
The designation and presentation of the scope of application must be consistent with the purpose of
the code, relevant in the context of the regulatory framework, and appropriate to the intended
subjects. The Code of Conduct for Ethiopian NGOs identifies its scope as covering “all signatories,
which fall under the definition of NGOs in the Code of Conduct and operate in Ethiopia”. In the
definition of the Code, an NGO is “a voluntary, not-for-profit, non self-serving, non-governmental, non-
partisan and independent organization or association involved in the promotion of social justice and
development” irrespective of features such as level of operation, religious or secular nature, or form
of organization. Although the same provision of the Code refers to other informal or formal groups,
this definition covers the whole range of structures in the civil society sector.
The issue of consistency with the purpose of the Code, already identified as aligning the role of NGOs
to current development challenges, does not pose much problem. Such a broad scope is in fact
necessary if the Code is to achieve its stated purpose. The same was also true for the other criteria at
the time of the Code’s development. However, changes in the legal framework since the late 1990s
may have implications for the relevance and appropriateness of the above definition. For one, there
are no longer NGOs but charities and societies designated Ethiopian, Ethiopian resident or foreign
with their potential roles and areas of engagement determined by law. This will have implications for
the profile of intended subjects as well as the purpose of the Code. Thus, while the scope was
relevant and appropriate at the time of development, its continued propriety needs to be reassessed
in the current context.
2.3 Vision, values and guiding principles
The design and presentation of shared visions, missions, principles and values in a code of conduct
has to be seen in terms of providing sufficient detail to inform a comprehensive accountability
framework as well as relevance to the regulatory context as well as propriety to the profile of
intended subjects. The last point relates to whether the shared value framework is compatible with
the organizational vision, mission, principles, and values of potential signatories.
The Code of Conduct for Ethiopian NGOs does not articulate a vision. It has however explicitly
identified the shared mission of NGOs operating in Ethiopia as improving and advancing the public
good, the quality of life of those who are disadvantaged and vulnerable and the proper management
of the environment for future generations. This shared mission is to be achieved through initiatives
to empower and build community capacity, provide services for sustainable development, and work
in partnership with each other the Government donors community partners and the public. Though
presented as standards of conduct, the Code also contains statements of principle and values. These
are, in order of presentation, people centered, fairness and equality, moral and ethical integrity,
transparency and accountability, good governance, independence, communication and
collaboration, gender equality, environmental consciousness, sustainability, and impact.
As general statements of aspiration, mission statements, principles and values are hardly responsive
to changes in context. This is especially true for the Code’s statement of mission which had been
designed to accommodate a range of institutions falling within its scope. Moreover, conflict with

5. organizational profiles is not likely to arise since the elements of the value framework have not been
clearly defined. However, the statements can barely inform the development of specific rules and
implementation framework for the Code for the same reason putting their very utility in to question.
For instance, since there is no stated vision and none of the principles and values of the Code have
been identified as such, a conceptually consistent link cannot be made at any level. It would thus be
necessary to overhaul the general section of the Code and develop a comprehensive, internally
consistent and clear set of principles and values in line with a shared vision and mission.
3 Specific Rules and Policies
This section of a code of conduct is expected to cover, at the very least, four core issues. These are:
the internal governance rules for organizations, accountability rules, rules for professional conduct,
and complaint procedures.
The Code of Conduct for Ethiopian NGOs has a section dedicated to “Standards of Conduct”
understood as the norms to which signatories of the Code are expected to adhere. These standards
are presented in the form of declarations of commitment under the principles and values dealt with
in the previous section. While the generality of the statements may be a concern, issues of internal
governance have been covered under the ‘good governance’ provisions of the section. Similarly, the
‘transparency and accountability’ and ‘people-centered’ provisions deal with issues relating to
accountability rules, while the ‘fairness and equity’, ‘moral and ethical integrity’, and ‘independence’
provisions deal with individual conduct. One could thus surmise that the Code makes reference to
the core issues that are expected to be dealt with in the specific rules section. However, the
presentation of this section as well as the gaps identified in the value framework raise concerns as to
whether the formal existence of provisions is matched by sufficiently detailed, consistent, and
relevant standards in the substance of the rules.
3.1 Internal Governance
A code of conduct is expected to have rules on internal governance that are stated clearly and in
sufficient detail, consistent with the general provisions of the code, relevant in the context of the
regulatory framework, and consistent with the organizational rules of intended subjects. A
sufficiently detailed statement of rules should at least cover issues of separation of management and
governance, transparent and democratic rules and procedures governing appointments and
elections, terms of office, and balanced regional or gender representation. Consistency with general
provisions, on the other hand, is about the congruence with the rationale and objectives of the code,
and the shared value framework (vision, mission, principles and values). Since the same issues of
internal governance are normally dealt with through legislation, comparable rules in a code of
conduct have to take into account mandatory legal stipulations on internal governance structures,
mandates, processes and standards. Similarly, the constituting documents of potential members
have to be taken into account in designing the code provisions.
The good governance provision of the Code of Conduct for Ethiopian NGOs contains commitments:
to have a written constitution or a memorandum of association that clearly defines our
mission, our objectives and our organizational structure;

6. develop a written policy that affirms our commitment to equal opportunities in: our
employment practices; the promotion of staff; and board composition; and,
ensure that the services of the governing body is given freely and voluntarily other than
reimbursements for essential costs incurred during service.
Other issues of internal governance, such as separation of functions or membership rules, are not
dealt with in the Code. Moreover, since these same provisions form the general section and owing to
the generality of the same, it is not possible to consider whether the rules of internal governance are
consistent with the general provisions of the code or relevant in the context of the regulatory
framework. The same is unfortunately true for consistency with the constituting documents of
potential subjects.
3.2 Accountability Rules
The proper design and presentation of rules on accountability will be clear and address the key
elements of accountability in sufficient detail in line with the general provisions of the same code,
the regulatory framework, and the organizational rules of intended subjects. The details expected in
this part relate to rules addressing both downward and upward accountability in the form of
mechanisms such as regular reporting, financial independence and transparency, sound financial
management and accounting, annual audited financial statements, and annual general meetings as
well as participatory processes.
The ‘transparency and accountability’ provision of the Code of Conduct for Ethiopian NGOs starts
with a general commitment to be transparent and accountable in dealings with all stakeholders,
including the Government and community partners, the public, donors and other interested parties.
This is specifically stated in the context of informing stakeholders on the origin and use of resources.
Accountability mechanisms enumerated within the commitments under this provision include
making available periodic audit, financial and activity reports, developing sound financial policies and
systems, conducting independent annual audits, and making reports available to ‘relevant and
interested parties’. The provision also includes a commitment to conform to the constitution, laws,
rules and regulations of the Government of Ethiopia and, where necessary, lobby for change. The
provision on people-centeredness in the Code of Conduct for Ethiopian NGOs also refers to a
commitment to involve all the men, women, young people and children of target communities to the
greatest possible extent, making them responsible for the conception, implementation and
evaluation of projects and programs.
These provisions of the Code clearly address the key issues falling within the scope of accountability
rules in terms of accountability to key stakeholders, mechanisms and participatory processes to
engage beneficiaries. Consistency with the mandatory regulation framework as well as propriety to
potential members, i.e. charities and societies, is also not a major concern since the same issues are
dealt with by law. The only concern here, other than the challenge of comparison with general
provisions of the Code, is the reference to some of downward accountability mechanisms which is
too general for meaningful implementation. A case in point is the commitment to involve
beneficiaries in programming, which is not covered in the relevant legislation.

7. 3.3 Rules of Professional Conduct
Assessment of code of conduct rules on professional conduct relates to examining whether the rules
are stated clearly and in sufficient detail and consistent with the general provisions of the code, the
legislative framework, and the profile of organizations to be governed. These rules are expected to
provide clear standards of behavior-permitted and prohibited - in a range of situations, define
conflict of interest, and stipulate the development of organizational code of conduct.
The provision of the Code of Conduct for Ethiopian NGOs on ‘fairness and equity’ commits
signatories to exercise and promote fairness, impartiality and equity in all of their activities and in
dealings with interested parties, community partners and the general public. Similarly, the ‘moral and
ethical integrity’ provision refers to commitments to be truthful, refrain from practices that
undermine the moral and ethical integrity of organisations, and utilize resources for designated
organizational purposes. The issue of conflict of personal and professional interest is also mentioned
under the ‘good governance’ provision. These provisions do touch upon the core issues of
professional conduct. However, the generality of statements as well as lack of clarity as to the ‘how’
of acceptable conduct is likely to make them impotent to guide behavior. For instance, the Code
neither defines ‘conflict of interest’ nor commits signatories to develop rules on the issue. In fact,
these provisions of the Code more properly identify general values rather than standards of conduct.
In this context, it is not possible to assess whether the provisions are consistent with the general
provisions of the code, relevant in the context of the regulatory framework, or appropriate to the
profile of potential signatories. One point that is clear is that the mandatory provisions on conflict of
interest provided for in the current regulatory rules provide a more useful set of standards. (CSP
stipulations on officers; conflict of interest in the regulation)
3.4 Compliant Procedures
Rules on compliant procedures, properly designed and presented, take into account the potential
concerns of external and internal stakeholders, direct organizations to assign a designated
ombudsman, and provide for protection of whistleblowers. Consistency with the regulatory
framework and propriety for the expected profile of signatories are also important. The NGO Code
of Conduct for Ethiopian NGOs has stipulated detailed rules on who may lodge a compliant and to
which organ, procedures for consideration, and appeal in its code observance section. These
provisions are stated clearly and in sufficient detail and are in line with the general provisions of the
Code, which they are designed to implement. Consistency with the regulatory framework is not a
concern since the procedures supplement legislative processes such as stipulations on mandatory
disclosure of misconduct. The only concern here relates to protection of whistleblowers and the
potential benefits of assigning an ombudsman.
4 Implementation and Enforcement
This section of a code of conduct is expected to cover three key issues: identifying implementation
challenges, putting in place mechanisms for implementation, and enforcement provisions. At the
outset, implementation challenges should be clearly identified and addressed. Implementation
mechanisms, on the other hand, should provide sufficient detail on the structures and procedures,
responsible persons or bodies, and regular reporting mechanisms. It is also advised that signatories
be directed to develop an implementation strategy for the code of conduct as a whole. Finally,
enforcement mechanisms should be stated clearly and in sufficient detail including non-compliance

8. reporting mechanisms, consequences to apply in cases of breach, a system of positive incentives,
awareness and dissemination, and assessment and review of the code.
The Code of Conduct for Ethiopian NGOs does not identify implementation challenges. It does
however provide in detail for implementation mechanisms including the establishment of code
observance structures and mandates. Gaps in this respect relate to the absence of provisions
directing signatories to designate a code observance officer and absence of regular reporting
mechanisms. Enforcement mechanisms stated in the Code cover non-compliance reporting
mechanisms, a range of soft measures as well as the possibility of cancellation of membership by the
General Assembly, a system of positive incentives, awareness and dissemination, and assessment
and review of the code.
4.1 Process of Development
Evidence of a process involving analysis aimed at addressing the four key questions of
accountability described earlier – who, to whom, for what, and how, as well as a possible
fifth – with what outcome?
Establishing shared values among intended subjects of the code
Engagement of all stakeholders, especially beneficiaries
Approval at the highest levels
5 Conclusions and Recommendations
5.1 Conclusions
5.2 Recommendations