From the earliest days of the PEACE Programmes, managing communications has been one of the most difficult challenges for SEUPB, the Managing Authority.
This became apparent during PEACE I, where the implementation model was centralised, controlled by Government Departments and Agencies, and the emphasis was on a Marshal Plan style economic regeneration programme. It soon became clear that addressing the legacy of the conflict involved much more than rebuilding border crossings and bombed-out buildings. Both the beneficiaries and the funders began to ask what was distinctive about the PEACE Programmes that set them apart from any other regional regeneration initiative.
When the SEUPB was set up in 1999 as an independent Body, created as part of the North/South Institutional Architecture contained in the Good Friday / Belfast Agreement, the emphasis shifted towards delivering a more distinctive Programme, emphasising reconciliation, with a commitment to the principles of social inclusion, equality of treatment for all, and addressing the visible and invisible legacy of the conflict. This placed communications at the heart of the programme design and implementation challenge.
As Managing Authority of the PEACE Programmes, the SEUPB was required to occupy a neutral space in a deeply divided society. These divisions did not disappear with the signing of the Good Friday / Belfast Peace Agreement. What the Agreement provided was a commitment to respect these differences while working towards a society that was fair to all. The PEACE Programmes were the practical embodiment of this commitment for the communities on both sides of the border, and it was the duty of SEUPB to give content and meaning to the ideal of inclusiveness and equality of treatment for all.
Over the years, this challenge has required the SEUPB to demonstrate and manage political neutrality in all of its actions, making it safe and acceptable for all to access the funding that was being provided for the projects that were embedded in different communities. In practice, this entailed engaging with elected representatives at local and national level from all political backgrounds; engaging with Government Departments under the management of Ministers from different political parties; establishing deep-rooted relationships and partnerships within communities throughout the region representative of the broad diversity of culture, beliefs and convictions; funding projects aimed at addressing the needs of both former combatants / ex-prisoners from all sides of the conflict and victims of the conflict, including the survivors of those who had died or been seriously injured. This task was made even more complex by the requirement to operate and manage all of this on a cross-border basis, encouraging engagement between communities from different religious and political backgrounds on each side of the border.
Inevitably, when large amounts of funding are involved, accusations of bias arise from different sides over the course of the years of programme management. This has served as a stimulus to the programme managers to develop innovative methods of determining community engagement and community uptake, and of furthering their understanding of what reconciliation means in practice in divided societies emerging from many years of bitter conflict.
In addition to the requirement to be neutral and trusted by all sides, the SEUPB was also obliged to adhere to a demanding set of both EU and National regulatory and governance requirements, including managing and accounting for the communications dimensions of EU funded programmes. As part of this process of being seen to be neutral, projects in receipt of funding were required to put in place a communications strategy, including the organisation of public events that promote the objectives and achievements of their work. These activities have a significant cumulative value over the years in building a consolidated picture of unbiased engagement across all sides of the community and geographic reach of the programmes.
The management discipline needed to comply with the regulatory requirements of communications, helps to create an environment of transparency, openness, and equality of treatment for all. This is an essential pre-condition for the successful management of the more complex communications issues facing those involved in promoting reconciliation and shared-society-values in post conflict situations where deep divisions persist. It is worth exploring some of these thoughts in more detail.
Communications and Regulatory Compliance
The Managing Authorities of EU funded programmes are obliged to comply with a wide range of regulatory provisions. These are specified in a suite of regulations that are agreed at the beginning of every seven-year programme period. They have the force of law within the EU, and they are part of the contract that every Member State and its nominated Managing Authority enter into with the EU. The regulations cover every aspect of the design, preparation, planning, financing, implementation, management, reporting, and accounting of the programmes. The commitment to a Communications Strategy for each programme is one of those regulatory requirements.
Under normal circumstances and for normal ERDF and ESF funded programmes, this commitment is predominantly a technical compliance issue. It involves a range of management provisions in the areas of information, publicity, awareness raising and, acknowledgement of the EU dimension of the funding that has been used.
In the case of the PEACE Programmes however, where the task is to reinforce progress towards a peaceful and sustainable society and to promote reconciliation and where the objectives include activities aimed at Reconciling Communities and Contributing to a Shared Society, and addressing the legacy of the conflict, communications becomes much more than a technical compliance challenge. It is an integral part of the way in which the programme is designed and managed and it is a central plank of the management strategy of the managing authority. It is also a key competence and skill set required of the programme managers.
While the technical compliance requirements for the Managing Authority of the Peace Programmes have evolved over the years since PEACE I, the overall pattern has remained the same. The regulatory requirements for PEACE IV are representative of the kind of commitments that both programme managers and beneficiaries have always been required to undertake in the management and use of funding.
A dedicated communications officer is appointed for the programme, responsible for drawing up a communication strategy in line with the provisions of the regulation. This strategy sets out the overall approach to be adopted for information, publicity, and communications by both the programme managers and the beneficiaries. This strategy must be approved by the Monitoring Committee of the Programme, who are also responsible for regular monitoring of its implementation. An annual report on the implementation of the communications strategy is provided to the Monitoring Committee and to the European Commission as part of the Annual Implementation Report (AIR) that programme managers are required to prepare.
The communications officer also commits to engaging actively with a network of programme communications officers throughout the EU. The purpose of this networking is to share experiences and learn lessons from other regions and programmes. In this way, the communications strategy of the programme forms part of the wider EU communications strategy and feeds into the wider dissemination and promotion work of the European Commission. It is part of the EU’s commitment to transparency in its operations and, as such, is an essential component of the governance arrangements for the EU as a whole.
A central component of the programme communications strategy is the website and / or portal that is developed by individual programme managers. This is intended to provide a platform that facilitates access to all information regarding the programme for use by potential beneficiaries, the general public, civil society, the media, and the public administration authorities at national, regional, and local level within the country.
The website should contain a list of all the projects (also referred to as ‘operations’) funded by the programme. This should include details on the amount of funding that has been made available, the purposes for which the funding is to be used, the organisation responsible for the management of the project, and the geographic location of the project. Agreement to publish this information is a part of the contract that each beneficiary enters into on signing the ‘letter of offer’ (a term used for the contract that is entered into when an application for funding is approved). The collation of this information is intended to assist in publicising information on the impact, results, and achievements of the programme and of the funds that are used.
The website should also provide potential beneficiaries, or intended applicants for funding, with all the information they require regarding the disbursement of funds. This should include clear information about the dates for the issuing of invitations to apply for funding under each of the programme objectives; a description of the procedures that will be followed in the management of the call for applications; a description of the criteria and procedures that will be applied to the assessment of applications; and an indication of the date by which the call for applications process will be completed and awards of funding made. This information is essential in order to ensure that all applicants for funding are guaranteed equal access to all the information they need to make a successful application, including making available, where possible, templates that can be used in the drafting and submission of applications.
The website also provides information on public information events, seminars, workshops, communication days that are organised to promote the work of the programme. These include seminars that are aimed to assist potential beneficiaries in the preparation of their applications. An important part of this process is the provision of detailed information and guidance material on the kind of expenditure that is eligible for funding under the programme; the requirements that beneficiaries will face in terms of publicity and information as part of their contract, including the rules in relation to the use of logos and emblems of the EU, the programme, and of the funds; and what kind of technical assistance and support they can expect from the programme managers in the preparation of their application and in the eventual successful management of the project / operation.
The communications, publicity and information activities of the programme are central to the management of a successful programme. The communications officer undertakes to organise a major information event at the start of the programme period to publicise the launch of the Operational Programme and kick-start the roll-out of the programme implementation process. In addition, every year a major information event is organised which promotes the funding opportunities available within the programme; the strategies that have been pursued; the achievements that have been attained, including examples of projects / operations that have been funded.
Beneficiaries are required to include, in their project application and implementation plans, details of the steps that they intend to take to comply with the information and publicity requirements of the programme. They are also required to report periodically on the implementation of the project, including the fulfilment of their obligation in the area of communications. They are provided with assistance in this task by the communications officer and the programme management staff and they are also provided with a budget to finance the communications dimensions of their project. Compliance with this requirement is subject to periodic audit and non-compliance can be deemed an irregularity, which, depending on the seriousness of the infringement, can attract penalties, including financial penalties.
A full copy of the PEACE IV OP is available on the SEUPB website. A shorter version, entitled Citizens Summary is also provided. On page 66 of the OP there is a list of the specific objectives for communications, under the section dedicated to the Technical Assistance element of the programme. This list provides a summary of the key commitments made by the PEACE IV programme managers to comply with the technical requirements of the regulations and the outputs that are to be produced as part of the management of the programme.
The technical compliance element of the communications function in PEACE Programmes has not been universally popular with beneficiaries. It is often associated with tedious and tiresome issues related to the use of logos and publicity materials on buildings and on project promotion material and ensuring that the contribution of the programme and of the EU is acknowledged and recognised in all manifestations of the project that has been funded. Compliance has frequently been characterised as a bureaucratic imposition that gets in the way of the substance of the work of the projects. Non-compliance can result in the declaration of irregularities that attract the imposition of financial penalties. Project managers sometimes feel that this imposition gets in the way of their freedom in the achievement of the key objectives of the programme.
It is difficult not to feel sympathy for some of these criticisms. Compliance can be a heavy burden on smaller projects run by informal community-based groups that lack management capacity and expertise. This was one of the reasons why the managers of the PEACE Programmes have over the years sought to award project funding to clusters of projects led by a Lead Partner who takes ownership of the bureaucratic compliance of project management and fills the gap in capacity experienced by smaller groups. The Lead Partner could bring much needed expertise in financial management, project management, governance, and accountability. This should in theory remove these burdens from smaller local based groups and free them up to concentrate on the local based content of the project.
Despite the difficulties that regulatory compliance imposes on beneficiaries, it is not unreasonable to expect those in receipt of substantial funding to contribute to the achievement of the broader communications objectives of the Programmes and the dissemination of its key messages. There are in addition, many significant advantages to be gained from an insistence on compliance with core communications requirements.
One of the great advantages of the PEACE Programmes in a divided society emerging from many years of bitter and violent conflict, has been the fact that the funding and the interventions have managed to create a neutral space between opposing groups and identities. The funding that is made available is seen as belonging to all and available to all on equal terms. Doubts about this neutrality during the early days of PEACE I, were tackled in a very radical way by the commencement of a process of regular community uptake analysis. This was followed up by a persistent programme of outreach to those communities who felt that they were not receiving their fair share, in an effort to overcome the reluctance to make applications and to build their capacity to engage, These engagements helped to reinforce the concept of neutrality and equality that is central to the public perception of the programmes. A disciplined communications strategy, as described above, reinforces these perceptions, and values and reinforces the reputation of the Managing Authority as being transparent, credible, trustworthy and non-partisan.
Divisions between communities in Northern Ireland and the border counties of Ireland, where the conflict was most evident, have resulted in deep rooted suspicions that do not disappear overnight or on the signing of an agreement. Community representatives, elected representatives and the media outlets that are identified with a particular community, carefully monitor the roll-out of the PEACE Programmes to satisfy themselves that there is no unfairness or discrimination in the distribution of funds or in the way in which their communities are being treated. The SEUPB is required to report regularly to parliamentary committees on both sides of the border, and to the Monitoring Committee that has been set up for the purpose of providing oversight, and which is representative of all sides of the community. In such an environment, it is essential that the management of the programme in every aspect is completely above reproach. This is what the implementation of a well-planned and well delivered communications strategy provides. It combines transparency and accountability, with fairness and proactive commitment to all sides, regardless of their role in the conflict.
 Regulations for the European Structural and Investment Funds for the period 2014 to 2021 can be viewed at: https://ec.europa.eu/regional_policy/archive/information/legislation/index_en.cfm
 For the Programme period 2007 to 2013, the general regulation containing common provisions for all the funds was: Council Regulation (EU) No.1083/2006; and for the period 2014 to 2021, the common provisions regulation was: Council Regulation (EU) No. 1303/2013.
 For the period 2007 to 2013, see: Council Regulation (EU) No.1083/2006, Article 69; and for the period 2014 to 2021, see: Council Regulation (EU) No. 1303/2013, Article 115 and Annex XII.
 Council Regulation (EU) No. 1303/2013, Article 115 and Annex XII.
 The term Operational Programme (OP) is used to refer to the document that is prepared by the Managing Authority at the start of a programme period. It is prepared after an extensive period of wide consultation and, in the case of the PEACE Programmes, is agreed by the Members States (United Kingdom and Ireland) before being submitted for approval to the European Commission. The OP outlines in great detail the strategy to be followed by the Programme; the results and impacts it expects to achieve; the funding that will be used; and the management and implementation arrangements that have been agreed.
 British Irish Agreement Act 1999; see: http://www.irishstatutebook.ie/eli/1999/act/1/enacted/en/pdf