A year ago, on May 5, 2022, President of Ukraine, Volodymyr Zelensky, announced the creation of the UNITED24 fundraising platform. It was supposed to become the main "window" for collecting donations to support Ukraine from international partners, donors, and philanthropists. The funds were planned to be used for the needs of the Armed Forces of Ukraine, humanitarian aid, infrastructure restoration, and counteracting russian aggression.
Over the year, according to official estimates, the platform has raised $328 million. These funds were transferred to the accounts of three departments: the Ministry of Health, the Ministry of Defence, and the Ministry of Infrastructure. However, it later turned out that eight other ministries also raised funds under the UNITED24 brand, making collectively an additional $451 million. Thus, the total amount according to preliminary calculations is $779 million, or 28 billion UAH at the official exchange rate.
On the UNITED24 portal, the report on the receipt and use of funds is updated weekly, but it is presented in a generalised form. The public only sees a table with daily receipts, as well as the name, quantity, and cost of the equipment purchased. At the same time, there is no information on who supplied the goods and who received them. No confirming documents regarding the movement of funds and purchases of goods are published.
Mind, with the support of the NGO State Watch, tried to find out: how these donations are collected and distributed, how they are accounted for, and who is responsible for this.
How does UNITED24 raise money? It's a unique procedure in the history of Ukraine. "Effectively, these are non-budget accounts, an account opened with the National Bank, where ministries could use the funds according to their own procedures," explains Martyna Boguslavets, Executive Director of the Institute of Legislative Ideas. "This mechanism has never been used before. These were non-budgetary funds, so the usual control procedures were not applied."
An analysis of the inflow of donations to the accounts of ministries under the UNITED24 brand
What does UNITED24 raise money for? Funds are being collected through the platform in the following areas nowadays:
- Defence and demining (the Ministry of Defence's account for raising funds to support the Armed Forces);
- Medical assistance (the Ministry of Health’s account for meeting health care needs);
- Rebuilding Ukraine (Ministry of Infrastructure’s Fund for the Restoration of Destroyed Property and Infrastructure account);
- Education and science (Ministry of Education’s account for meeting the needs of education and science);
- Demining (Ministry of Economy’s account for financing humanitarian demining activities).
An audit of expenditure was to be carried out quarterly by the reputable international company Deloitte Ukraine. But as of May 5, 2023, there is no publicly available data on the results of such an audit. The Mind team sent a request to the company, but had not received a reply at the time of publication.
How are expenditures from UNITED24 accounts regulated? Public activists analysed all the regulatory framework concerning the disposal of these funds, studied all open sources, sent more than 30 requests for public information to relevant ministries, and carried out an anti-corruption expertise.
For instance, the Institute of Legislative Ideas points out that 11 ministries have opened their own accounts under the UNITED24 brand. But effectively, the only accounts for the platform are those of the Ministry of Health, the Ministry of Infrastructure, and the Ministry of Defence. Additionally, accounts for the Ministry of Education and for the Ministry of Economy are now being created under the UNITED24 brand for humanitarian needs. Therefore, there are only five official accounts in total where the global community collects funds.
However, a much larger amount – $451 million – which was collected over the year under the UNITED24 brand by eight other ministries: the Ministry of Social Policy, the Ministry of Reintegration, the Ministry of Digital Transformation, the Ministry of Education and Science, the Ministry of Culture and Information Policy, the Ministry of Youth and Sports, the Ministry of Veterans Affairs, and the Ministry of Economy, is currently outside the scope of independent auditors.
Formally, these accounts are referred to as UNITED24 accounts by Government Resolution No. 472, but no data or reports on the expenditure of this amount have been published anywhere. In other words, the document provides for fundraising for 11 accounts under the UNITED24 brand. Meanwhile, the platform is only raising funds for three accounts, with two more to be added shortly.
Why are an additional eight ministries in question? According to Martyna Boguslavets, there has been no audit carried out for the other eight ministries’ accounts, similar to the one conducted for the accounts of the first three agencies. There is no information published about the funds collected and spent. "The creation of all these other accounts is not reputationally supported by ambassadors. And they are not promoted at the international level. So this is essentially an in-house initiative of the ministries," she notes
Ministries use the UNITED24 brand because it helps to raise funds faster. However, no one controls the process of spending this money within this charity programme. For example, the Ministry of Education collected 47,000 UAH in donations in 2022. But as soon as the ministry's account was added to the platform, $1 million was collected on the very first day.
Also, activists have found that some ministries are concurrently raising funds for the same needs. For example, both the Ministry of Infrastructure and the Ministry of Health use funds for the reconstruction of healthcare facilities. Experts believe that this also creates corruption risks, so such situations should be avoided.
This leads to confusion among donors about the nature of the accounts and creates reputational risks for the idea of helping and rebuilding Ukraine. As a result, resources are used chaotically, and responsibilities are duplicated. Therefore, public activists recommend clearly separating the accounts under the UNITED24 brand, which have been added to the fundraising platform, from other accounts supporting Ukraine.
Can this process somehow be structured? "The StateWatch think-tank has developed a model of an online tool for controlling medical expenses with the support of the International Renaissance Foundation. This portal focuses all information about what is being purchased, who is purchasing for the funds of UNITED24 in the field of health care, who makes decisions on what to purchase, what is the price per unit of goods, how this medical product is then distributed throughout Ukraine, and also what needs the medical institutions have, which come from the de-occupied territories to the Ministry of Health with the aim to ask for funds for reconstruction," says Glib Kanevsky, Head of the StateWatch.
According to him, based on an analysis of the distribution of funds in health care, several simple recommendations have been prepared on how to ensure transparency of spending.
To begin with, all documents (records) have to be published about what and who is being purchased from, at what price.
Secondly, all requests from local self-governments and medical institutions and other entities controlled by the ministries have to be published. That is, specifically what funds are being requested for, and accordingly, information about which requests have been met and which have not. "So that the logic is clear, who is primarily given money for reconstruction, who will be given money in other turns, or will not be given at all," explains Glib Kanevsky.
All reports on expenses must be absolutely logical and be published in two languages: Ukrainian and English. "A lot of donors outside of Ukraine would like to see full reports in English," he adds.
Analysis of the use of funds (an example): Balance of United24 for medical care and medical infrastructure restoration, June 2022 – April, 2023
Who and how spends the money collected on UNITED24? Local self-governments, regional state administrations, municipal- and state-owned enterprises submit applications with projects for financing. A special commission, created by each ministry, decides what to spend the funds on. These commissions consider applications for financing and publish protocols of their meetings with reports on decisions made on the official ministry websites.
Recipients of funds can be authorities at all levels, as well as organisations of any ownership, charitable foundations and non-government organisations.
Public activists, following their own analysis, state: not all ministerial commissions work transparently so far. For instance, information about all submitted applications, agendas, committee records is not published, there are no expenditure prioritisation criteria, meetings are not broadcasted. Therefore, the public cannot control the distribution of funds.
For example, although the official website of the Ministry of Health has a special sectionwith the records of the Commission's meetings "on the distribution of funds to meet health needs", these data are not systematised. Therefore, analysing the effectiveness of expenses made is hard.
StateWatch analyst Anastasiya Khymychuk points out: to ensure the transparency of the use of money collected under the UNITED24 brand, it is necessary to set prioritisation criteria: what approach is used to refuse some and allocate funds to others. "And it is necessary to inform the public in advance about when the commission meeting will be held, what issues will be considered," she adds.
This is what the public report on the receipt of funds for the restoration of destroyed property and infrastructure looks like now on the UNITED24 platform. There is no information on what the money was spent on.
How do the funds distribution commissions work? "The commission reviews applications submitted to them by state bodies or local self-government bodies," explains Martyna Boguslavets. "The procedures indicate the direction they can allocate to. For example, the Ministry of Health can purchase transport, restore hospitals, repair equipment and so on. Not the ministry, but directly municipal enterprises and state bodies manage these funds. In some ministries, such funds may be allocated manually. And there is no word at all about the composition of the commission, the requirements of the commission, how it should work and manage these funds. And this entails huge corruption risks."
Usually, commissions consider applications behind closed doors. They are not limited by any criteria or the need to justify their decisions. Ministries transfer money to selected applicants. Applicants organise procurement on their own. Control over this process is formal.
How to fix this? In order for the process to be transparent, public representatives should be included in the commission's composition. As of now, there are no criteria by which some projects are considered a priority and others are less important. Such commission meetings should take place online. And anyone interested should have the opportunity to view the video of the meeting in the web archive – for understanding what is happening, how voting takes place, what priorities funds are allocated according to, and to whom.
In addition to this, in the opinion of the public, it is necessary at the level of a bylaw (Resolution of the Cabinet of Ministers No. 472) to develop clear procedures for the commission's work. And provide for how the commission votes, what the commission does, and how it makes decisions.
"In most ministries, the commission is made up exclusively of ministry employees. Our requirement is for the independent work of commissions, which distribute funds in ministries – with the definition of clear norms for the composition of this commission, defining the percentage ratio of the public and ministry employees," proposes Ms. Khymychuk.
A fragment of the record of the Interdepartmental Commission for Considering Appeals and Preparing Proposals on Funds Distribution under the UNITED24 project meeting on February 20, 2023
The Ministry of Digital Transformation disclosed information about the amounts of money received upon requests. That is, in fact, applications that were made for reimbursement. They organised an independent review of the commission and identified specific reasons for refusing to satisfy the request for funding.
The Ministry of Restoration published a list of all submitted appeals, attached materials, their consideration status, draft acts on the distribution of the fund's money. Now on the ministry's website, there is an online broadcast of the meetings of the Interdepartmental Commission and a video archive of broadcasts.
"This is also very important, because we do not understand why funds are allocated to some objects, for example, one school located in a region where combat operations were waged, but not to another such school," activists emphasise.
To alter the lay of the land with fundraising, StateWatch and the Institute of Legislative Ideas propose amendments to the Procedure for using official accounts for donations in support of Ukraine UNITED24.
"In partnership with the Ministry of Digital Transformation, we have worked on amendments to resolution No.472, which concerns all accounts," says Martyna Boguslavets. "We provided a huge amount of recommendations during our research to the relevant directorates of the Ministry of Digital Information. We co-operated with a large number of ministries and over eight months provided our recommendations on how the reconstruction process can be made much more transparent. It is necessary to develop a unified procedure for systematising and publicising data on the income and expenditure of funds across all areas of income as part of the UNITED24 project."
How to make the process of Ukraine's reconstruction more transparent? The ideas from civil activists on amendments to the Cabinet of Ministers' Resolutions No.472 and No.1286 are:
- define transparent procedures for the use of funds and reporting;
- divide accounts for the collection of voluntary contributions into ministry accounts and accounts that are located on the UNITED24 platform;
- provide that funds for the reconstruction of damaged/destroyed immovable property will be allocated from the account of the Ministry of Infrastructure;
- publish data on income and expenditure in Ukrainian and English;
- publish proposals for the allocation of funds;
- submit requests regarding the distribution of funds for the reconstruction of damaged/destroyed immovable property through the DREAM system (Digital Restoration Ecosystem for Accountable Management) – a state electronic ecosystem that provides a single digital route for all reconstruction projects. Communities can create their own projects, present them to international partners to attract financial resources and manage the construction process.
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