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NASCOH Annual Report for Year Ending March 2011

nascoh October 28, 2013

 

 

1. Programme Identification Details:

 

GTF Number 88
Short Title of Programme Enfranchising People With Disabilities to exercise their constitutional right to vote and facilitating their inclusion in governance systems.
Name of Lead Institution National Association of Societies for the Care of the Handicapped (NASCOH)
Start date 12/11/2008
End date 31/12/2014
Brief Summary of Programme: A five year programme seeking to secure the  inclusion of people with disabilities (PWDs) in  Zimbabwe’s governance systems through their participation in all elections, run for local and parliamentary elections in their respective constituencies, advocating for  polling stations accessibility to people with disabilities (PWDs) and are able to vote secretly and independently. The programme aims at ensuring proportional representation of PWDs in parliament and other decision making bodies, a quota system in employment, lobby for the creation of a disability ministry, enactment and implementation of conducive disability legislation by the government. At the moment PWDs do not vote, and are apprehensive about the indignity of being assisted by a stranger.

 

List all countries where activities have taken or will take place Zimbabwe

 

Target groups and wider beneficiaries People with Disabilities in Zimbabwe

 

Person who prepared this report  Fambaineni Innocent Magweva

Disability Technical Advisor

NASCOH

93 Greendale Avenue, Greendale

Harare Zimbabwe

Tel +263 4 2900041/ 776 291 4449

Email. imagweva@yahoo.co.uk

 

2. List of Acronyms

COPAC Constitution Parliamentary Select Committee

CSOs Civil Society Organisations

DFID (UK Government) Department for International Development

DWSO Disabled Women Support Organisation

DPOs Disabled People’s Organizations

GTF Governance and Transparency Fund

ITC Information, Technology and Communication

JJA Jairos Jiri Association

M&E Monitoring and Evaluation

MOU Memorandum of Understanding

MOV Means of Verification

MP Member of Parliament

MTR Mid Term Review

NCA National Consultative Assembly

NASCOH National Association of Societies for Care of the Handicapped

NIEEB National Economic and Empowerment Board

NIEF National Indigenisation and Empowerment Fund

NYC National Youth Council

NGOs Non- Governmental Organizations

PWDs People with Disabilities

RAMs Rapid Appraisal Methods

SRC Sports and Recreation Commission

WGI Worldwide Governance Indicators

ZAVH Zimbabwe Association of Visually Impaired

ZEC Zimbabwe Electoral Commission

ZESN Zimbabwe Election Support Network

ZILGA Zimbabwe Local Government Association

ZIMNAD Zimbabwe National Association of the Deaf

ZIMNAMH Zimbabwe National Association for Mental Health

ZMC Zimbabwe Media Commission

ZNLB Zimbabwe National League of the Blind

ZPHCA Zimbabwe Parents of Handicapped children Association

 

 

 

3. Executive Summary

 

This third annual report covers all the activities carried out on the programme on ‘Enfranchising people with disabilities to exercise their constitutional right to vote and facilitating their inclusion in governance systems’ during the period from March 1 April 2010 to 31 March, 2011.

 

The programme intends to achieve the following by the end of the funding period;

  1. Produce disability friendly legislation including the national constitution, national disability policy and Acts of parliament which have direct bearing on the lives of people with disabilities, especially those dealing with issues of accessibility.
  2. To have at least 400 elections observers with disabilities who will monitor all coming national and local elections
  3. For people with disabilities to be able vote in local and national elections
  4. For people with disabilities to be appointed to positions of authority, elected or nominated as Councilors, Members of Parliament.

 

NASCOH realised that the success of the programme is grounded, among other factors, on a strong and vibrant disability movement which is able to make the government responsive and accountable to the needs of people with disabilities. In order to achieve the said results, the major activities conducted during the period under review included organisational assessment visits to ten member of NASCOH’s members, election observer workshops, which brought the total of PWDs trained under the programme to date to 287, leadership training for Directors and board members, programme review workshops, audit of five Acts of parliament ( the Electoral Act, Labour Act, Education Act, Urban Councils’ Act and the Indigenisation and Empowerment Act),  a media-disability sensitisation workshop, distribution of assistive devices including wheelchairs, catheters, crutches and urine bags, training workshop with political parties, and a disability sensitisation workshop for commissioners, provincial election officers and key staff of the Zimbabwe Electoral Commission (ZEC), the country’s sole elections management body.  Most of these events received extensive coverage in the local press. During the period under review, disability received several media mentions mainly due to cordial relations that NASCOH has managed to cultivate with the media.

 

The weekly radio programme ‘Seka urema wafa’ which profiles disability issues and concerns was on the air every week for the 52 weeks of the year. The live phone-in radio programme, which is aired on ‘National FM’ every Saturday from 6.30pm to 7.00pm, focuses on cross cutting disability issues that impinge on the participation of people with disabilities in all spheres of life, including issues of inclusion the country’s  governance systems.

 

Disability sensitization of key stakeholders at national and district levels also took a centre stage. Chief among these was engagement of political parties to include a sizeable number of people with disabilities, in their activities.. Disability sensitization also targeted, employment bodies, the Zimbabwe Electoral Commission (ZEC), Constitution parliamentary select committee (COPAC), eight Urban Councils, seven rural district councils, other Civil Society Organizations (CSOs) such as the National Consultative Assembly (NCA), churches, business persons, community leaders such as councilors, chiefs, headmen, village heads and families of people with disabilities

The commemoration of the International Day of the Disabled took place in all the programme areas and beyond.

 

With the assistance of district elections officers from ZEC a large number of  over six thousand, (6444) people with disabilities received voter education. The programme also engaged the registrar general’s district offices who issued birth certificates and national Identity documents to hundreds (503) of people with disabilities. A number of people with disabilities (PWDs) were registered as voters.

 

Over seven hundred (750) People with disabilities (PWDs)  received training on human rights; as a result quite a considerable number of PWDs (45) want to stand as candidates in the next general elections. Almost all local authorities in the seven districts appointed or agreed to the appointment of special interest councilors with disabilities.

 

During the period under review, the programme also focused on the appointment of PWDs in the public and private sectors and in local committees. As a result hundreds of PWDs were appointed to positions of authority.Using what has been achieved to date the programme is destined to achieve higher results than anticipated.

 

4. Programme Management 

No change since last report.

 

5. Working with implementing partners

No change since last report.

6. Risk Assessment

Risk Assessment Table

 

 

Risk Potential impact Probability Mitigation measures
Risk 1.Political Uncertainty Medium  there are widening differences in the inclusive government, thus raising the prospect of the agreement coming unstuck Medium  Working with all political parties in the inclusive government
Risk 2. Early elections High -The country is still to heal from the 2008 general elections which were characterised by violence. The country has already started to experience political violence in some areas. Medium  

Lobbying together with other civil society for elections to held when there is a new constitution and conditions are conducive for the holding of credible elections

Risk 3  MDC T might pull out of the inclusive government

 

High- The MDC T has threatened to pull out of the inclusive if the political situation does not improve Medium – SADC is committed to ensuring a peaceful solution to the Zimbabwean situation and has the ear of all the parties. Civil society organisations (CSO) continue to lobby the principals of the Global Political Agreement (GPA)

 

Risk 4 Weak implementing partners High

Lack of competent finance staff at two sub grantees

High The two sub grantees have been asked to recruit competent finance staff to ensure quality accounting throughout the programme.

 

 

Risk 5 Possibility of Deregistration of some NGOs and curtailing of activities High- in the event it happens Low- ZANU PF wants to redeem its name

 

NASCOH encourages its member organisations to be apolitical and work with the principals of the Global Political Agreement (GPA)

 

 

7. M & E Arrangements

There have not been any significant changes, to the M & E arrangements and M&E personnel, resources and activities continued to be assigned during the period according to the specifications of the Inception Report.  The most up-to-date M&E operational plan is included as annex A2 of this report.

 

8. Log frame Changes

No changes have been made to our log frame. However, the Mid Term Review (MTR) which ended in May 2011 and Triple Line Consulting recommended that the Log frame should be reviewed. Hence the log frame is being reviewed under a different process. The original log frame is attached as annex 2.

 

9. Emerging impact on governance and transparency

See Annex A9

 

10. Cross-cutting issues

This section describes how the programme is targeting people with disabilities and the positive and negative impacts in relation to PWDs.

 

The programme introduced to the sub grantees knowledge about governance and built their capacity for advocacy on the rights of PWDs. In all the areas the sub grantees had taken action to ensure inclusion of PWDs. A major impact was the setting up of the disability and advocacy committees at ward level in which PWDs now have a structure for articulating their needs and making input into development programmes. In all the project sites there are examples of sub grantees taking action to influence local authorities and service providers. In all the sites there had been approval to nominate a PWD as a special interest councilor.

 

PWDs participated in the Constitution Parliamentary Select Committee (COPAC) outreach exercise. PWDs were accepted as a special interest group and represented as team members in the outreach teams and as rappotuers. Only 318 PWDs participated in the general outreach meetings which offered little accessibility to PWDs.  After advocacy by DPOs and NASCOH a special countrywide outreach programme specifically targeting people with disabilities was organised.  This ensured that the voices of PWDs were captured fully in the outreach process. As a result a total of 7 963 PWDs were now reached representing 0,72% of the country attendance of COPAC meetings.

 

Besides the input the constitution, five Acts of parliament were audited for inclusiveness in preparation for advocacy work with parliamentary portfolio committees. These included the Electoral Act, Labour Act, Education Act, Urban Councils’ Act and the Indigenisation and Empowerment Act.

In the aspects of election observation over 287 PWDs have been trained as election observers. This is an increase from 77 elections observers who observed the 2008 general elections. In addition, ZEC raised  NASCOH’s status to that of strategic partner.

 

The programme has assisted 446 PWDs in getting national identity documents (birth certificates and identity cards), which they did not have before and in some districts to register as voters. The voter education targeted at PWDs with the assistance of ZEC has resulted with many PWDs expressing interest to vote in the next general elections. ZEC, with the assistance of NASCOH, is putting in place accessible voting facilities and voter education material to ensure access by PWDs to election centers and to voter education materials. To date ZEC had also approached a designer to come up with an adjustable voting table to enable wheelchair users to vote with dignity. The Electoral Act has been amended to allow assisted voters, for example the visually impaired persons to be assisted by a person of their choice as opposed to the past practice where an assisted voter was assisted by agents of political parties, polling officers and the police.

 

All the rural district councils where the project is being implemented have agreed to appoint special interest councilors from among PWDs and are only awaiting the approval from the Minister of Local Government. NASCOH has entered into discussions with urban councils on the same issue and the response has been positive. This is a big achievement considering the short period that the project has been operational.

 

During the period under review, NASCOH and sub grantees used ZILGA, the umbrella body for local government structures in the country, to facilitate the appointments of special interest councilors with disabilities, appointment of PWDs in Ward development committees and other local positions of authority.  The table below shows information on special interest councilors who were nominated during the period under review.

 

 

District Name of Special interest councilor Type of Disability Gender
Mutare Munyaradzi Mafondokoto Physical Male
Masvingo rural Vangai Chirugu Physical Male
Mudzi Zano Kahuni physical Male
Mudzi Mordecai Munokori Physical Female
Mberengwa Innocent Dube physical Male

 

 

To date, National Economic and Empowerment Board (NIEEB) has appointed 13 PWDs as resource persons to the 13 Sector specific Committees of the board.  Further, the thirteen sector policy drafts which have been submitted to the cabinet for approval significantly include disability related issues.

 

As a result of this programme targeting PWDs, local authorities such as the Gwanda Urban Council and Mutoko Rural District Council have come up with new by-laws that make it compulsory for all new buildings approved by the Council to accessible by PWDs. In addition the councils in Mutoko, Masvingo, Mutare and Bikita have constructed ramps to enable access by PWDs.

 

In addition to the vehicles provided in 2009 the programme was able to provide motor bikes to enable outreach to the most remote areas. Ward Disability Committees also conduct door to door visits to those who are severely disabled, to prevent exclusion of those that are bed ridden and those living in remote inaccessible areas.

 

The programme has made a major impact on the lives PWDs through   boosting self-confidence of PWDs that participated in the programme. The result is that several PWDs indicated their intention to contest for council elections, which they would not have thought possible before. The provision of assistive devices, including wheelchairs, white canes and hearing aids, had a huge impact on the lives of beneficiaries who are now more mobile or better able to hear. For instance, chiefs in Masvingo and Mberengwa  who had  physical disabilities, are now able to perform their functions,  thanks to the wheelchairs purchased under the programme.  Increased mobility for PWDs has also boosted their self-confidence, which in turn has increased their participation in the community affairs and governance structures as well as livelihood projects.

 

 

 

11. Progress towards sustainability

 

By improving governance in the sub grantees as well as in NASCOH, the programme had ensured that PWDs are served by the organisations that claim to represent them.

 

The programme introduced to the sub grantees knowledge about governance and built their capacity for advocacy on the rights of PWDs. In all the areas the sub grantees had taken action to ensure inclusion of PWDs. A major impact was the setting up of the disability and advocacy committees at ward level in which PWDs now have a structure for articulating their needs and making input into development programmes. In all the project sites there are examples of sub grantees taking action to influence local authorities and service providers.

 

The programme has improved the capacities of both NASCOH and the sub grantees, which is demonstrated by the ability of the sub grantees to lobby engage rural district councils and the ability of NASCOH to lobby ZEC for the amendment of the Electoral Act, COPAC for an outreach targeting people with disabilities. The capacity building of sub grantees has resulted in some the sub grantees like ZAVH getting funding from African Development Foundation (ADF) to the tune of $250 000.

 

As a result of their improved capacities, partners (sub grantees, ZEC and district councils) have compiled registers of PWDs broken down by type of disability and gender to ensure proper targeting of the groups with interventions, in preparation of the next general elections. This information is also use by the councils to create budget lines for PWDs, for example, Mberengwa Rural District Council has created a budget line for PWDs to assist them with food, among other provisions, which is another important step in mainstreaming disability. In Mutoko, as a result of the programme, the participatory budgeting exercise for the next financial year will include a budget line for Disability. It is envisaged that all local authorities in all the programme will have budgets for PWDs and continue to provide services even after the GTF programme has ended.

 

The setting up of Disability Ward Committees in all programme areas and the incorporation of a representative of PWDs from the Disability Committees into the Ward Development Committees ensures that the views of PWDs are heard at ward development meetings and is an effective way of mainstreaming disability into development. The Ward Disability Committees which have received training on lobbying, advocacy and disability rights from sub grantees have started lobbying local leaders such as councilors, chiefs and schools development committees for inclusion of PWDs in all spheres of the community. The lobbying by the Disability Committees has mostly been done without the assistance of the sub grantees. A good example is the Disability Committee in Masvingo district Ward 29 (Nyikavanhu) which has lobbied local business persons to make their premises accessible. The committee has also successfully lobbied for access to all livelihood programmes in the area. The livelihood programmes are mostly carried out by NGOs such as Heifer International and Care International. This is a sign that the disability committees will continue to function effectively after the GTF programme has ended. Before this programme PWDs were left out even from relief programmes.

 

The disability committees have been strengthened by the appointment of PWDs as special interest councilors in all the seven districts of the programme. All the rural district councils where the project is being implemented have agreed to appoint special interest councilors from among PWDs and are only awaiting the approval from the Minister of Local Government. NASCOH has entered into discussions with urban councils on the same issue and the response has been positive.

 

The involvement of community leaders, MPs, councilors, political parties and business people in the programme has enhanced its sustainability. Politicians want numbers and PWDs provide a niche for candidates who want to win elections.

 

The sustainability of the programme also lies in the continuation of voter education programmes for PWDs, by ZEC, issuing of identity documents and registration of voters with disabilities by the registrar general’s office at district or sub district level, after the end of UKaid funding. The ZEC strategic plan identifies PWDs as key stakeholders and NASCOH as a strategic partner in ensuring inclusion and accessibility. Disability also appears in the five year strategic budget and ZEC is currently working with NASCOH to develop voter education material.  To this end, ZEC has developed a specific funding proposal to target PWDs and other vulnerable groups.

 

NASCOH has continued to collaborate and network with other organisations such as the Zimbabwe Election Support Network (ZESN), Zimbabwe Local Government Association (ZILGA) through meetings and information sharing workshops. NASCOH is a key partner in ZESN’s country strategy on elections. ZILGA has also embraced disability as a key talking point to all local authorities.

 

More sustainable changes are expected with the changes in legislation and laws brought about as a result of the programme. The adequate capturing of disability in the country’s constitution, amendment of the Electoral Act and many other Acts, combined with the abilities of disability committees to demand equitable services will make the government and CSOs accountable and responsive to the needs of PWDs. Furthermore, the acceptance of the principle of special interest councilors for PWDs by councils combined with the amendment of the Urban Councils’ Act is likely to result in cooption of councilors  with special interest throughout the life span of the councils. Also significant is the legislation making it compulsory for new buildings being approved by councils to have wheelchair access (in the case of Gwanda and Mtoko).

 

The changes to operational procedures including alterations to polling booths and polling stations to allow easier access by PWDs, increase in the number of polling stations to accommodate PWDs, preparing ballot papers in Braille as well as adoption of a disability policy and amendment of some Acts of Parliament will increase the sustainability of the programme.

 

12. Innovation

The programme has come up with a number of innovations. However,  one which stands out among the rest is the promotion of self representation by PWDs starting from the village to national level.

 

This was done in stages, starting with mainstreaming disability at local level- the setting up of Ward Disability Committees is an innovative way to mainstream issues of disability in a sustainable manner. PWDs are also  represented by a PWD in all wards Development Committees. This is then strengthened by the appointment of special interest councilors at district level. The programme was innovative in making use of the provision to ensure representation by PWDs. The disability representatives make sure PWDs have access to equitable services. As result of the lobbying of the disability committees in some districts like Chivi, Mberengwa and Mtoko, the register general’s office operated mobile registration for birth certificates and identity documents. In districts like Masvingo, PWDs were registered and benefitted from livelihood programmes which they never accessed before.

PWDs are among the poorest of the poor in society. Use of  the disability committees and special interest councilors and by focusing on PWDs has enabled the poorest of the poor to participate in governance.  Despite the political polarization and volatility in Zimbabwe the programme managed to get councils in programme areas to work together on issues of inclusion of PWDs. The use of local PWDs in disability committees or as special interest councilors, for lobbying, removed the suspicion associated with CSOs in Zimbabwe. The programme has for the first time succeeded in meaningful awareness-raising among traditional leaders on issues of disability. In Mutoko and Masvingo after the awareness training conducted by the disability committee, two of the chiefs have passed a ruling against anyone using terms that are not disability sensitive. Those that do so pay a fine as punishment.

 

13. Learning from GTF

 

Access to public services

Relevance

Prior to programme interventions PWDs, due to age old attitudes were relegated to the margins of society, further they had difficulties in accessing essential services offered by government departments.  Such services include public assistance, and registering as voters, chiefly because they did not have national identity documents.  Since the programme was introduced, the programme has assisted 446 PWDs in getting national identity documents (birth certificates and identity cards), which they did not have before and in some districts to register as voters. 5782 PWDs benefited from the voter education undertaken by ZEC. ZEC, which now considers NASCOH as a strategic partner, has indicated that it is  putting in place facilities for ensuring enhanced access by PWDs to polling places as well as addressing issues of putting election  and voter education material in accessible formats such as, large print, Braille and sign language to cater for the visually and hearing impaired.  These groups have traditionally  been marginalised with respect to accessing election- related essential services.

 

Quality of Service

The programme has led government through the registrar-general’s department to introduce mobile voter and national identification registration units.  Such units are particularly important to those poor PWDs who find it difficult to travel to urban and semi-urban centers were the services are mainly available.  While essential services at most rural district councils were generally available to most residents, it was not the same case with PWDs who found it difficult to access most public buildings.  Due to such inaccessibility availability of essential services to PWDs remained a pie in the sky.  Thus the programme led to some local authorities adjusting all public buildings to make them accessible to PWDs.  Mutoko Rural District Council for example made a commitment to adjust all public buildings which were not accessible to people with physical disabilities.  NASCOH lobbied the Constitution Select Committee (COPAC) to have a consultative outreach programme specifically tailor made for PWDs and 7900 of them participated. In the general outreach programme 23 PWDs participated as either team-members or rapporteurs and questionnaires used by Outreach team members were put in accessible formats such as Braille and large print in order to cater for the visually impaired and the partially sighted.

 

Availability of essential services

Mobile national identity(and birth certificates) and voter registration was readily available to PWDs in the hard to reach areas.  In some cases the registrar general’s department and the Social Services department jointly formed mobile units to ensure that poor PWDs who needed social protection were at the same time registered for public assistance administered by the department of social services.  Distribution of assistive devices like wheelchairs, crutches, urine bags and catheters remains very low to make any meaningful impact and NASCOH is making efforts to ensure the sourcing of these vital mobility and empowerment devices, which have special implications for disability inclusion.

 

Reduction of Costs of essential services

In travelling to and from services centers some PWDs were forced to pay their own bus fares, fares for wheelchairs where applicable and for their assistants.  This has fortunately been reduced through the introduction of mobile birth, identity and voter registration units.   PWDs have had to be accompanied by assistants to service centers in their locality thereby increasing the social burden and cost of disability management.  Assistive devices have thus significantly reduced both the financial and social cost of disability management.

 

Improvement of Relationships between governments and citizens with disabilities at local and national levels

Rural and urban councils, through continuous interaction with sub grantees at local level and NASCOH at national level understand Disability better than before and are now willing to include disability in their programmes. PWDs have already assumed posts of special councilors in some local authorities.  The preparedness by ZEC to work with NASCOH in providing voter education to PWDs and the /training of election observers is evidence of the strong relations cemented by the programme.   The involvement of other government departments in the programme and institutions in the programme such as chiefs, provincial and district administrators, the police, the registrar-general and social services has solidified government’s strong identification with the programme.   Maintenance of the momentum gathered, coupled with proper exit strategies gives the programme a high potential of receiving future government moral and financial support long after sub-grantees have pulled out of the districts in which they are currently operating.

 

Media and governance

 

In order to put pressure for reform on the government to stop systemic and endemic abuse of human rights across the board , broad civil society coalitions like Crisis in Zimbabwe Coalition(CiZC) and the National Association of Societies for Non Governmental Organisations (NANGO)  have increasingly resorted, especially over the past year, to putting numerous adverts outlining civil society demands in the press, supported by the signatures of its member organisations in a show of solidarity. Examples include a statement on key civil society demands on the 2011 National Budget published under the banner of NANGO in The Standard of October 31-November 6, 2011 and the civil society joint statement on escalating violence, increasing instability and targeted victimization of civil society leaders, the media and ordinary citizens, a full page advert published under the banner of CiZC in The Standard of March 27 to April 2, 2011(page 22).

 

The independent media has virtually become an extension of civil society, serving not only to articulate its demands but highlighting human rights abuses perpetrated by the government on civil society.  Serious financial papers like the Financial Gazette, and Zimbabwe Independent and The Standard, which previously eschewed coverage of disability issues, now routinely publish human rights issues on disability including the signing of the United Nations Convention on the rights of people with disabilities, budgetary implications on PWDs and marginalised groups, and lack of service delivery.  Examples include an article entitled “Disability treaty; Government under pressure” published in the Financial Gazette of March 3-9, 2011 and an article titled “Boy shows that disability is not inability’ published in The Standard newspaper of November 14-20, 2010.

 

Through media advocacy and strategic highlighting of pertinent disability issues in the press, NASCOH has now been able to put disability on the agenda of the press resulting in both public and independent press focusing on marginalisation and inclusion issues of PWDs.  Annual Disability-Media workshops have served to reinforce the partnerships with the press. The communication strategy is grounded on the use of multiple and complementary channels of communication to ensure optimum knowledge management and information sharing.

 

 

 

Annex A

 

 

Annex A1 – Achievement Rating Scale 

 

 

 

Annex A2 – Programme Log frame

 

Annex A3 – Annual Financial Report

 

Annex A4 – Material produced during the reporting period

See Annex 4

 

Annex A5 – Web Update for your programme

See Annex A5

 

Annex A6 – Annual Workplan

See Annex A6

 

Annex A7 – Local Partners List

No changes in local partners have occurred since our last report.

 

Annex A8 – Main Contacts List

No changes in main contacts for our programme have occurred since our last report.

 

Annex A9 – Short Articles about the emerging impact of your programme

 

Annex A10 – M&E Operational Plan

 

Annex B

 

Annex B1 – Detailed budget for all project years

The detailed budget for all project years has been given under Annex A3.

 

Annex C1 – Any Outstanding Issues from previous reports

The two issues which have been outstanding from feedback letters from KPMG were;

  1. Review of the Log frame pertaining to Baselines, Purpose statement, Verifiable Indicators and
  2. The MTR management response to the MTR’s recommendations which was “lightweight, incomplete – only 6 of the 12 principal recommendations are addressed – and gives no indication of the timeframe required for implementation” have been dealt with adequately in the MTR management response to MTR feedback which were sent together with this report.

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