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SDGs African Independent Auditors

Draft Concept paper v 1.0

The SDG challenge is immense. To realize the SDGs, it is estimated that the world will need to invest a staggering amount
of between USD 5 trillion and 7 trillion per year – roughly 7%-10% of global annual GDP. To put these numbers into
perspective, total investment into the Apollo Space Program (1963-72) to put a man on the moon was approximately USD
150 billion at present value.
Credible Data and innovative public policies are needed to ignite change. To achieve the SDGs by 2030 will require new
and innovative solutions that challenge traditional socio-economic models and approaches. Many of these solutions will
need to be viable as well as deliver value to society.
Talents must be mobilized. Harnessing the next generation of leaders is critical if this is to be possible – they bring fresh
perspectives, open minds, different values, tech savviness, and an appetite for disruption.


Despite that the SDGs have been criticised for their shortcomings (1), they started to shape much of
the international aid, cooperation and investment agenda. In total, many trillions of USD are needed
to achieve those SDGs by 2030. In this framework, the EU, which is largest global donor has adopted
in 2017 a new common framework for its development cooperation policy in support of the
implementation of SDGs (2)

The Africa-EU strategy (JAES) which is the Africa- EU partnership guidance tool defining the strategic
orientation of the Partnership identified cooperation for the implementation of SDGs as one of its
main priorities (3) and the EU has set up an External Investment Plan Euros 44 billion crowding fund
aimed at African private businesses (4) working within the framework of SDGs.

It seems therefore that SDGs implementation is the most secure way for African countries to attract
investment and improve socio-economic situation, hence scrutinising the published data on the
progress done towards achieving 2030 Agenda is a crucial exercise for both the populations targeted
by SDGs to determine the public policies impact on their lives as well as for the donors and investors
to insure that the money they are bringing is serving its purpose, lastly, such scrutiny would reduce
the risk of data manipulation.

SDGs data collection and analysis

The report “A world that counts” elaborates nine key principles for the data revolution for
sustainable development. The report underlines the necessity of periodic audits by professional and
independent third parties in order to demonstrate the high quality and integrity of statistical
information, especially in light of non-traditional data sources such as big data and geospatial
information (Independent Expert Advisory Group on a Data Revolution for Sustainable Development,
2014) (5) The IEAG report recommended in 2015 the launch of an SDG Data Lab for SDG monitoring
through the mobilisation of stakeholders (6)

The data included in the 2018 Global Index and Dashboards that will be used in this article come
from a mix of official and non-official data sources. Most of the data come from International
Organizations (World Bank, OECD, WHO, FAO, ILO, UNICEF, other) (7),

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SDGs data scrutiny

To insure a quality stats for the SDGs, international organizations are urged by the UN to base the
global review on data produced by National Statistical Systems and, if specific country data are not
available for reliable estimation, to consult with concerned countries to produce and validate
modelled estimates before publication (8)

Supreme audit institutions have a key role to play in auditing programs to achieve SDGs. Such audits
can determine whether governments are meeting their commitments, achieving planned results and
putting in place policies and programs that work. Audits can lead to improvements in the way
programs are designed and delivered. SAIs can take four approaches to help achieving the SDGs at
the national, regional and global levels:

- Assess the readiness of national systems on progress towards achieving the SDGs and
subsequently audit their operation and the reliability of the data they produce
- Undertake performance audits that examine the economy, efficiency, and effectiveness of
key government programs that contribute to specific aspects of the SDGs
- Assess and support the implementation of SDGb16, which relates in part to transparent ,
efficient and accountable institutions
- Be models of transparency and accountability in their own operations, including auditing and
reporting (9)

In the developing countries however, the independence of SAIs, their resources and capacity to audit
the SDGs can’t be taken for granted. In fact SDGs are a new subject for them and their may be a
steep learning curve to overcome - for audit planning to be affective, auditors need to understand
the 2030 Agenda and acquire solid understanding of the government’s programming in relation to
implementing, monitoring and reporting on the SDGs.

In the next chapter, we try to analyse the results of SDGs progress for Tunisia as a case study with the
aim to check the credibility of the indicators and the scores. We base our analysis on the data
provided by SDG Index and Dashboards Report for Africa (10)

Tunisia Case Study

Macro-economic context of the SDGs.

Tunisia lives in a democratic transition since 2011. Prior to that, the dictator Ben Ali, famous for
manipulating data, succeeded to market the country as a model of development (11) , unfortunately,
the world chose to ignore all the red flags of the dictatorship and hailed its ‘economic achievements’
(12) . Both International Financial Institutions and the UN, through its UNDP Human Development
indicator failed to address the issues that triggered 2011 revolution. Today, Eight years on, it looks
like we’re back to square one: Despite an explosive socio-economic situation, Tunisia ‘made it’ again
to the 2nd position in Africa, with high SDGs score this time.

Hence the question: Is the world is being fooled again. Are we told the truth about the reality on the
ground or is that history is just repeating itself. Unfortunately, we find that the data manipulation
and masking of realities didn’t go away in the transition to democracy. SDG data shows an
improvement in the overall wellbeing of the population because the national data provider chose to
dismiss from the indicator set important indicators that truly reflect the deterioration of the quality
of life of the average Tunisian.

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In fact, the current socio-economic issues find their roots in the wrong development model adopted
by the ex-regime and that didn’t change after the 2011 revolution, not only the post –revolution
instability and socio-economic after-chocks continued to impact negatively the country, Tunisia
creditors made sure since Deauville summit in 2011 (13) that the country gives up its sovereignty by
tying up their assistance to the Tunisian economy to the implementation of neo liberal reforms,
which, Deauville partnership stakeholders argued, would solve the country problems and boost the
growth. Those ‘partners’ also failed the nascent democracy by refusing to erase the odious debt
contracted by the dictator which meant depriving the country from funding its development.

Eight years later, Tunisia finds itself is at the edge of bankruptcy, in 2019, it has to disburse 3.2 billion
USD to pay back its debts (14) which, IMF admits is unsustainable and represents huge burden for
future generations (15) which represents the double of the money that is going to the development
effort. The imposed neoliberal reforms will lead to more poverty and rise in inequalities and
therefore undermine the achievement of SDGs.

With no money to invest in the development in general and in the SDGs in particular, it’s rather
astonishing that neither the 2018 UNDP Human Development Index (16) nor the SDG Tunisia Index
captured what the average Tunisian citizen experiences on the ground and while everybody expects
that the social time bomb will go off again at any time, little is being done to correct the path and it is
very likely that the IFIs will continue ‘supporting’ the ‘Tunisian model just like they did with the ex-

SDGs data collection, analysis

The National Institute of Statistics (INS) that is directly or indirectly one of the major sources of
information for the SDG Index and dashboard has a credibility issue related to data collection and
analysis methodology in a finding by the Tunisian Court of Auditors, the country’s Supreme Auditing
Institution (SAI), that stated in its 30th report, that INS is incoherent with the international standard in
the measurement of some trade related indicators (17). Since there was never been an independent
audit of the SDGs in Tunisia by the Court of Auditors, this finding of data corruption is a blow to
credibility of the reported SDGs indicators.

In fact, by adopting certain methodologies in measuring specific indicators of strategic importance,

INS tends to mask the reality. For instance, INS cites 2 million of illiterates, excluding from the
number, all those who have dropped out from the primary schools who grow by 100,000 each year.
If we add-up the figures since 1990, the total number today would be 2-3 million and therefore,
Tunisia would count some 4-5 million illiterates. Same for inflation, the rate that’s estimated to be
7.4% (8.1 % according to IMF) would be in reality 14-15% on average on all products. The difference
comes from the fact that INS doesn’t include in the data set the new consumer products (internet,
entertainment, ..). Employment data is also inaccurate, since is counted jobless, any person who
answers that he is at the time of the questionnaire by the INS investigator. When faced with
questions on its methodologies and the credibility of its work, INS blames other data providers as
well as the World Bank for the ‘imposed’ calculation methodology (case of poverty index) (18)

INS Data Gaps also include but not limited to Workforce information about the skills and training of
the workforce, more detailed data on the supply and demand for workers in specific industries
and/or occupations, and more detailed workforce projections; Education information relating to
adult and career education and more detailed school drop-out, enrolment and graduation data;
Health and Social wellbeing;

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There are also issue on Public service - Criticism of both the quality and quantity of information
available relating to the government sector is widespread. There is also a lack of performance and
cost measures for all levels of government, information about the local impacts of government
policies, and difficulties with obtaining data for at the local level as data is aggregated regionally.

SDGs Data auditing

On Feb 2019, the Court of Auditors stressed in its first ever SDGs- related work, done with a grant
from the Dutch Government (!!) , the need to set a legal framework that enables SDGs
implementation and to establish constitutional and executive structures for their monitoring and
enforcement. The court also asked the government of aligning its public policies with SDGs (20). In
other words, this report confirms that the Government of Tunisia didn’t walk the talk, and its
commitment to Agenda 2030 didn’t go beyond the signature of the UN Convention, For instance, the
GoT continues to borrow massively from abroad despite the warning from the UN Independent
Expert that unsustainable levels of foreign debt hinder the efforts of achieving SDGs (21)
On the other hand, the Court of Auditors said nothing about its failure in conducting the audit of the
SDGs indicators prior to their publishing in 2018 which is in contradiction of the UN
recommendations related to SDGs progress reports.

Discussion and extrapolation to Africa

Considering the flaws that we demonstrated in reporting the progress towards achieving SDGs in
Tunisia’s case, we believe that the SDGs process as a whole will be an utter failure unless serious
solutions are brought to correct some indicators that better reflect the realities and to insure an
independent scrutiny of data before its publication.

Both issues have been addressed by the UN –

- The first issue can be dealt with by introducing new indicators to better reflect the realities
by implementing UN recommendation that “each country should pick the number and range
of Complementary National Indicators that best suit its needs and capacity to collect and
analyse data” (15). This can be done through recommending African governments, UNDP
national offices and the National data providers to adopt evidence based indicators that
better reflect the realities on the ground.


SDGs Recommended Complementary Indicators

SDG1: No poverty UNDP Multidimensional poverty indicator
Breadth and depth of pro-poor social programs
SDG2: Zero hunger FAO Food Security indicators and specific indicators that
measure the sustainability of Tunisian agriculture as well as
the negative impact of the current production systems
SDG3: Good health Health spending per capita, ratio of Doctors per /1000
and wellbeing person, health budget per person, ratio of public vs. private
health institutions, people’s perception of wellbeing
Public health policy effectiveness
SDG4: Quality School drop-out per year, public education budget per
education student, ratio of public vs. private schools, people
perception of education

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SDG5: Gender Ratio of women holding a responsibility in the public
equality service abuse committed against women, gender pay gap,
SDG6: Clean water Contamination rate of water, state of water distribution
and sanitation systems, rate of bottled water consumption

SDG7: Affordable Access to gas grid, energy trade balance, energy prices
and clean energy sustainability
SDG8: Decent GDP share of the upper 1% of the population, rate of the
work and structural employment, impact of the pro-employment
economic growth programs
SDG9: Industry, level of maturity of national industries, number of
innovation and competitive industries, number of engineers per capita,
infrastructure number of engineers migrating abroad, coverage and
quality of public transports
SDG10: Reduced comparison between the richest and the poorest regions in
inequalities the country for various items such as GDP, employment,
life expectancy , income, etc.
SDG11: Rate of crimes in urban areas, perception of insecurity, the
Sustainable cities access to sports, cultural and entertainment facilities, ratio
and communities of green areas and playgrounds for kids, traffic
SDG12: Consumption of toxic chemicals, Resource productivity,
Responsible CO2 emission per km from passenger cars, energy
consumption and consumption, share of renewable energy, recycling rate of
production waste
SDG13: Climate Progress in setting adequate legislative framework,
action progress in INDC implementation, allocated budget of
climate action per capita.
SDG14: Life below Marine conservation, estimated trends in fish stock
water biomass, seawater bathing sites with excellent water
quality, mean sea acidity
SDG15: Life on Share of forest area, nitrate in groundwater, Phosphate
land pollution, estimated soil erosion, biodiversity index
SDG16: Peace, Death rate due to homicide, reporting occurrence of crime,
justice and strong violence or vandalism in their area, Physical and sexual
institutions violence to women, General government total expenditure
on law courts, Perceived independence of the justice
system, Population with confidence in the institutions
SDG17: Participation of youth, localisation of SDGs, Imports from
Partnership for the African countries,

- The solution to the second issue is also recommended by the UN but hasn’t been put into
practice yet “The necessity of periodic audits by professional and independent third parties
in order to demonstrate the high quality and integrity of statistical information” (5) . The
Introduction of a complementary audit of data, independent of SAI would reduce the risk of
SAIs dependence or failure to deliver 2030 Agenda due to lack of understanding, budget or

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SDGAIA Approach

By auditing the indicators that reflect the progress in achieving the SDGs, our approach is aligned
with SAIs in their mandate to review government SDG preparedness (22) through the auditing of the

Policy framework

1. Political commitment and recognition of national responsibility in line with the principles of
sustainable development

2. Building public awareness and encouraging dialogue with stakeholders including relevant NGOs,

3. Allocation of responsibility at a ministerial or other level, allocation of appropriate financial means

and other resources, and establishment of accounting arrangements

4. Preparation of plans to apply the SDGs including setting out the role of different stakeholders and
defining how the various goals and targets are to be achieved in an integrated and coherent manner

Data Framework

5. Designing and establishment of the systems to measure and monitor the SDG goals and targets

6. Setting baselines – the situation at the start of the process – for the different indicators, against
which to judge progress made throughout the SDG lifecycle

7. Monitoring and reporting arrangements on the progress of SDGs involving all relevant

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SDGAIA Structure

As the expected demand on those services can be high, the structure will be light, flexible and
scalable with a core team specialised in marketing, mission management and accounting and a
network of independent consultants and auditors drawn exclusively from the best African experts
that are specialised in SDGs and in public Auditing.
In its full fledge size, SDGAIA network will be comprised of
- Data and policy division – a network of 85 thematic advisors formed into 5 groups of 17
experts each covering SDGs and the 5 African regions to allow a fast response to demands
from around the continent.
- Network Support division that comprises of all what the network needs to function optimally
including coordination, capacity building, AMC (advocacy, marketing and communication),
mission management and accounting functions. The aim is to allow the network members to
focus on their areas of expertise.

The Staff
1 Network coordinator, representing the network at high level meetings and insuring its integrity
5 Senior Advisors covering the 5 regions – will be responsible for (1) selecting the independent
consultants from their respective region (2) Advocating the Governments and SDGs stakeholders and
marketing SDGAIA services in their region (3) Managing the consultancy missions (4) Insuring the
quality control of the deliverables
1 Accountant

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Freelancer Consultants recruitment
We will tap into professional social networks such as LinkedIn to search, identify and select the
members of our network.
To insure their commitment to the concept, prospective members will be asked to review the data
related to their field and country that’s published by ‘SDGs Index and assess its credibility.
This exercise will give a snapshot on the detailed work that will be done and will provide an excellent
tool to advocate the stakeholders on the need for an organisation such as SDGAIA.

Strategic partners
Public auditors’ capacity building The Tunisian Association of Public Auditors (ATCP) was created in
2011, its membership counts 140 public auditors. ATCP is a founding member of the Anti-Corruption
Civic Coalition and CSO’s Coalition for Transparency in the field of Energy and Mines. The Society
aims at promoting of the audit profession, consolidating the independence of the audit authorities,
building the capacity of public auditors, promoting the reform of the public administration through
transparency, accountability and community participation

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(1) None of the 17 SDGs includes a single mention of the word democracy or human rights,
some argue that SDGs are pushing an agenda carefully calibrated to avoid upsetting the
world’s dictators, kleptocrats, and this century’s worst human rights offenders. Others point
that SDG 16 (Peace, justice and strong institutions) represents the core values of the
democratic values without naming them

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Annex 1 – Assessing Tunisia’s progress towards SDGs, 2018
(based on SDG Index and Dashboard published data)

SDG1 No Poverty

Tunisia (and Africa) Indicators EU Indicators

- People at risk of poverty or
social exclusion
- People at risk of income
poverty after social transfers
- Severely materially deprived
- People living in households
with very low work intensity
- Population living in dwelling
with a leaking roof, damp walls,
floors or foundation or rot in
window frames or floor

The score is misleading, we recommend to add a complementary indicator of multidimensional


The adoption of the monetary dimension to measure poverty is misleading. It gives a convenient
ratio of 4%. We estimate that this is a wrong methodology for Tunisia. In fact the deprivation from
basic public services such as quality education and health, decent job and housing have increased
over the years due to the degradation of the socioeconomic situation in the country and this despite
the ‘official’ decrease in poverty figures. The adoption of the MPI elaborated by Oxford and adopted
by UNDP would give a more accurate picture of the reality of poverty on the ground (2)



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SDG2 – Zero Hunger

Tunisia (and Africa) Indicators EU Indicators

Obesity rate

Sustainable agricultural
- Agricultural factor income per
annual work unit (AWU)
- Government support to
agricultural research and
- Area under organic farming
- Gross nitrogen balance on
agricultural land

Adverse impacts of agricultural

- Ammonia emissions from
- Nitrate in groundwater
- Estimated soil erosion by water
- Common farmland bird index
- Grassland butterfly index

The drought and climate change are impacting severely the crop yield in Tunisia that is transformed
from the ‘Basket of Rome’ in the antiquity to a net importer of cereals. Tunisia produces today only
70% of its needs in wheat. Worse, the country imports up to 95% of the seeds up from 25% in 2004
making it food insecure country. (1) On the other hand, rising prices of staple foods and the risk of
reducing state subsidies are factors that will impact the growth of children. In fact stunting among
children increased from 9% in 2005 to 10.2% in 2016.

The imbalanced food quality in Tunisian diet where consumption of low nutritive pasta per capita is
among the highest in the world is increasing the adult obesity by more than 30% in 9 years, from
18.5% (1.3 million people) in 2005 to 24.2% (1.9%). million people) in 2014.
Finally, the rate of anaemic women of childbearing age increased from 27.8% in 2005 to 31.2% in
2016 present a sign of malnutrition(2)
We recommend using FAO food security indicators (3) to better assess the public policies on the
ground and to produce specific indicators that measure the sustainability of Tunisian agriculture as
well as the negative impact of the current production systems



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SDG3 – Good Health and Well-being

Tunisia (and Africa) Indicators EU Indicators

Healthy lives
-Life expectancy at birth
-Share of people with good or
very good perceived health

Health determinants
-Smoking prevalence
-Obesity rate
-Population living in households
considering that they suffer
from noise
-Exposure to air pollution by
particulate matter

Causes of death
-Death rate due to chronic
-Death rate due to tuberculosis,
HIV and hepatitis
-People killed in accidents at
-People killed in road accidents

Access to health care

-Self-reported unmet need for
medical care

The health system is in deep crisis and the score is misleading

This high score on SDG3 covers the systemic failure of the public health policy that is threatening the
collapse of the whole public health service

- The low wages in the sector is luring thousands of Medical Doctors to migrate abroad – They
were 800 who left to France alone in 2018 and 900 more are expected to leave Tunisia in
2019. (1)
- The lack of adequate resources and the rampant corruption in the public service impacting
the health infrastructure in the country which led to some catastrophes, including the death
in March 2019 of 12 new-born babies in a public hospital (2)

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- The bad debts of the social security funds (CNRPS and CNAM ) as well as of the Central
Pharmacy are threatening their very existence (3)
- The rise of world class private clinics widens the gap between the rich and the poor in terms
of access to quality health system

Polls on perception of wellbeing show that the majority of Tunisians are not satisfied with their lives

According the World Bank (4), the evolution of the monetary indicators of well-being seems to
contradict the perception of a decline in living standards emerging from household surveys.

Recommended Complementary Indicators would include: Health spending per capita, ratio of
Doctors per /1000 person, ratio of public vs. private health institutions, people’s perception of
wellbeing, number of doctors leaving the country


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SDG4 – Quality Education

Tunisia (and Africa) Indicators EU Indicators

Basic education
-Early leavers from education
and training
-Participation in early childhood
-Underachievement in reading,
maths and science
-Young people neither in
employment nor in education
and training

Tertiary education
-Tertiary educational
-Employment rate of recent

Adult education
-Adult participation in learning

This is obviously the worst assessment of the education sector in Tunisia.

It’s true that once, the education system was an asset as it produced generations of men and women
who built the country following the years of independence; a system that was free and accessible to
all, however, over time, the system failed to renew itself and cope with the ever growing number of
students. Today, the education lives a deep crisis that none of the initiated reforms has solved. Here
are some symptoms of the crisis

At the primary and secondary level

- Pre-schooling covers only 15% of children

- School drop-out reaches 100,000 students per year over the last 10 years (1)
- Infrastructure is aging and Education personnel are low paid, leading to an increase in strikes
and social movements that weakens further the system
- The various ‘reforms’ were ill designed and not inclusive
- The baccalaureate state exam results reflect the socio-economic divide in the country
between a rich coastal regions and poor interior. (2)
- Private education is flourishing with the blessing of the state which is also deepening the
divide (3)

At the university level

- The Brain drain of academics and researchers In the last years is accelerating, emptying the
universities from high skilled teachers and top graduates (4)
- The diplomas can no longer secure decent jobs: 1/3 of the 600,000 + unemployed are
university graduates, this can be explained by the inadequacy between job market needs and
university provided curricula. (5)

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- The university used to be the social ladder that enables people from humble social
background to make it to the top. This role is dead. Most of unemployed graduates come
from the disenfranchised areas of the country (6)

The recommended complementary indicators would include the pre-schooling rate, school drop-
out, ratio of private vs public education service, brain drain, education budget per student,
number of academics leaving the country, ..


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SDG5 – Gender Equality

Tunisia (and Africa) Indicators EU Indicators

Gender-based violence
-Physical and sexual violence
to women experienced
within 12 months prior to
the interview

-Gender gap for early leavers
from education and training
-Gender gap for tertiary
educational attainment
-Gender gap for employment
rate of recent graduates

-Gender pay gap in
unadjusted form
-Gender employment gap
Inactive population due to
caring responsibilities

Leadership positions
-Seats held by women in
national parliaments
-Positions held by women in
senior management
The real gender issues are ignored and the score is misleading

By including the indicators 1, 3 and 5 that are rated green because of the cultural mutation in the
society rather than actual public policies, the data leads to self-indulgent results, obscuring the real
gender discrimination issues lived by the Tunisian women including a higher then men’s school drop-
out. While the new political representation at the municipal and national levels show an increase of
women participation, we notice a discrimination in accessing decision making positions in both the
administration (only 2% ) and the private sectors (1) – Hence, the question why the INS has chosen
as indicator the last two ones (women ministers and parliamentarians) rather than ratio of women
holding a responsibility in the public service and other indicators developed by the INS itself in its
2015 Report on gender (2) such as abuse committed against women, pay gap, etc.



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SDG6 – Clean Water and Sanitation

Tunisia (and Africa) Indicators EU Indicators

-Population having neither a
bath, nor a shower, nor indoor
flushing toilet in their
-Population connected to at
least secondary wastewater

Water quality
-Biochemical oxygen demand in
-Nitrate in groundwater
-Phosphate in rivers
-Freshwater bathing sites with
excellent water quality

Water use efficiency

-Water exploitation index

Access to clean water is in jeopardy and the score is misleading

With the drought and desertification, Tunisia has a hydric stress that the current public policy, dating
back to the dictatorship era didn’t solve (1). This water policy reflects an ill-designed development
model that prioritises industry and tourism versus agriculture and by the same token coastal areas
versus the country interior. This imbalance finds its reflection in the distribution of groundwater:
rural communities who live nearby freshwater sources are deprived from it to the benefit of urban
dwellers and coast-based industries (2) which generates more pollution and contaminates
groundwater and the sea. The shortcoming of this SDG is that its set of indicators doesn’t include
some important indicators such as the contamination rate of water and yet, the country suffers
tremendously from the pollution of freshwater resources, the majority of these pollutants stem from
wastewater discharges, industrial effluents and agricultural activities, in fact, the intensive
agriculture and the generalisation of monoculture that requires use of pesticides

If we add to those factors, the health risk of aging copper water pipes used for the water distribution
(3) and the distrust expressed by the large public of the tap water quality, we understand the
continuous increase in the use of bottled water for which, Tunisia being ranked in the top 10
producers in the world. Of course, this trend excludes the poor and the low end of the middle class
who have no choice. We recommend to include the following complementary national indicators:
Contamination rate of water, state of water distribution systems, and rate of bottled water



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SDG7 – Affordable and Clean Energy

Tunisia (and Africa) Indicators EU Indicators

Energy consumption
-Primary energy consumption
-Final energy consumption
-Final energy consumption in
households per capita
Energy productivity
-Greenhouse gas emissions
intensity of energy consumption

Energy supply
-Share of renewable energy in
gross final energy consumption
-Energy dependence

Access to affordable energy

-Population unable to keep home
adequately warm

The SDG7 score is misleading

The high score hides the real crisis in the energy sector in Tunisia that will have tremendous impact
on peoples’ lives. In fact, Tunisia has an energy deficit of 45% and is expected to reach 77% by 2025.
(1) The natural gas, major source of electricity is today 8 times more expensive than what it was in
2000. This is caused by the rise of the imported gas bill, the slide of the national currency against the
dollar and the closure of local gas production plants due to strikes. The government tries to offset
those costs by increasing the subsidy on gas, however international financial institutions and other
creditors are demanding that the subsidy system to be cut or reduced dramatically and as those
latter have always the last word, it’s a matter of when and not if that this basic commodity will be
inaccessible to the lower classes. On the other hand, the coverage of natural gas network represents
only 65% of the households (2) and excludes rural population that are off the grid and have to rely on
gas cylinder for cooking.

Finally, the part of the renewable energy share in the total energy consumption (12.9%) is
exaggerated. The real value for 2018 is 3% according to the Tunisian Society for Wind Power (3)

We recommend the following Complementary National Indicators: Access to gas grid, Sustainability
of affordable access to clean energy


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SDG8 – Decent Work and Economic Growth

Tunisia (and Africa) Indicators EU Indicators

Sustainable economic growth
-Real GDP per capita
-Investment share of GDP
Resource productivity

-Young people neither in
employment nor in education
or training
-Employment rate
-Long-term unemployment rate
-Inactive population due to
caring responsibilities

Decent work
-People killed in accidents at
-In work at-risk-of-poverty rate

SDG 8 should be in red! The current economic policy showed its limits and only a paradigm change
can modify the situation.

Unemployment in Tunisia is the conundrum of a failed socio-economic model that dates back to pre-
2011. The IFIs and other adepts of the liberal order continue to support this broken model arguing
that an economic growth driven by the private sector will create jobs. But what we’re witnessing was
the total opposite. Despite all the programs and the billions allocated to incentivise the private
sector and to ‘launch’ the growth, the results are very meagre, the unemployment rate increased
and the growth didn’t happen, an average of 1.5 – 2% during the last years. On the other hand, the
number of millionaires have risen to over 7000 people while 70 individuals have a cumulated net
wealth of over 10 Billion USD (1) which is the quarter of Tunisia GDP! The World Bank admits that
despite that figures show a slight economic growth, people are not feeling any improvement in their
lives. While we don’t know whether the data has been manipulated or not, it is certain that if there is
any recorded growth, the common citizens didn’t benefit from it.

The DCFTA that’s being ‘negotiated’ with EU will lead to the closure of countless small industries and
the lay-off of thousands of employees (2), (3) while IFIs and other donors are pushing Tunisia to make
changes in the labour law to make it easier for employers to fire which is being opposed by trade
unions. Informal economy grew to the equivalent of 50% of GDP rooting the job insecurity and
precariousness. (4) Complementary indicators can include GDP share of the upper 1% of the
population, rate of the structural employment, impact of the pro-employment programs,


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Copyright Lotfi Kaabi PhD –
SDG9 – Industry, Innovation and Infrastructure

Tunisia (and Africa) Indicators EU Indicators

R&D and innovation
-Gross domestic expenditure on
-Employment in high- and
medium-high technology
manufacturing sectors and
knowledge-intensive service

R&D personnel
-Patent applications to the
European Patent Office (EPO)

Sustainable transport
-Share of buses and trains in
total passenger transport
-Share of rail and inland
waterways activity in total
freight transport
-Average CO2 emissions per km
from new passenger cars

The diversification of the Tunisian economy is seen by many as an asset however, it also shows the
lack of an industrial policy that harnesses the resources to build competitive and sustainable
industries. In fact, the IFIs imposed neoliberal model aim is not to create local competitors to the
western industrialists and multinationals, the idea was rather to guarantee and perpetuate access to
markets and to outsource labour intensive and polluting industries. In this endeavour, Tunisian
industry is condemned to stay small and never reach a stage where it can compete internationally,
while the country continues to attract FDI that comes for the cheap labour that gets even cheaper
with the artificial devaluation of the national currency. The privatisation programs encouraged by the
new liberal policy tenors is gaining ground and with it comes ‘flexibility’ in jobs and the sale of the
most profitable public companies.

With handful patents per year, the innovation is quasi absent and the resources allocated to R&D is
badly managed. Another alarming indicator is the growing number of skills departing the country.
According to the World Bank, Tunisia is ranked second only to Syria in the world in terms of
migration of skilled labor. In 2019, over 3000 Engineers will leave the country. (1) This brain drain
that’s invisible in the set of indicators means that Tunisia innovation potential is decreasing very

Recommended indicators would include the level of maturity of national industries, number of
competitive industries, number of engineers per capita, number of engineers migrating abroad


20- SDGAIA Draft Concept paper, V. 1.0, April 2019

Copyright Lotfi Kaabi PhD –
SDG10 – Reduced inequalities

Tunisia (and Africa) Indicators EU Indicators

Inequalities within countries
-Inequality of income distribution
-Income share of the bottom 40%
of the population
-Relative median at-risk-of-poverty
-People at risk of income poverty
after social transfers

Inequalities between countries

-Purchasing power adjusted GDP
per capita
-Adjusted gross disposable income
of households per capita
-EU financing to developing
-EU imports from developing

Migration and social inclusion

-Asylum applications

SDG 10 almost average score is misleading

Gini coefficient can’t offer any answer to the question « what happens to the richest and poorest
people ?, however this is a question that seems to concerns the most people. It’s not primarily about
all changes of income distribution, it’s about the lowest earners left behind in society and the highest
people changing ahead too far, and it’s about the poor and the rich.

The revolution happened in Tunisia because of the inequalities –

marginalisation of youth, disparities between regions in terms of
access to basic public services and the trend is accelerating after the
revolution (2) thanks to a neoliberal economic policy that produces
more inequality

This map highlights one root of inequalities – success rate in

Baccalaureate, that’s the national exam for the entrance in
universities. This rate reflects the socio-economic and social-justice
disparities between the regions.

Recommended complementary indicators include a comparison

between the richest and the poorest region in the country for various
items such as GDP, employment, life expectancy , income, etc.



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Copyright Lotfi Kaabi PhD –
SDG11 – Sustainable Cities and Communities

Tunisia (and Africa) Indicators EU Indicators

Quality of life in cities and
-Overcrowding rate
-Population living in households
considering that they suffer from
-Exposure to air pollution by
particulate matter
-Population living in a dwelling with
a leaking roof, damp walls, floors of
foundation, or rot in window
frames of floor
-Population reporting occurrence
of crime, violence or vandalism in
their area

Sustainable transport
-Difficulty in accessing public
-People killed in road accidents
Share of buses and trains in total
passenger transport

Adverse environnemental impacts

-Recycling rate of municipal waste
-Population connected to at least
secondary wastewater treatment
-Artificial land cover per capita
SDG 11 high score is misleading

Should the proportion of urban population living in indecent housing been taken as indicator instead
of those living in slums, the score would have been much lower. In fact, the land market is a major
factor in urban sprawl. On the one hand, illegal developers and landowners are at the origin of the
development of a specific land market for people whose income is modest and irregular. The sale of
small lots without infrastructure is a land product within the reach of these populations and can only
be marketed illegally in urban wasteland. The number of those houses constructed between 1970
and 1995 is about ½ million in Greater Tunis alone. In terms of housing policy, the state, unable to
produce a land supply suited to low-income populations, tolerates development on the outskirts of
this type of housing. The cost of this form of urbanisation is prohibitive because it involves the cost of
the loss of agricultural land, of infrastructure built a posteriori, of transport, etc. the activities in the
vicinity of these housing units are the cause of pollutant discharges with multiple impacts. Finally, the
state, by stepping up rehabilitation operations, accredits this type of housing, whereas it would have
been wiser to define a genuine social housing policy based on the provision of plots of land equipped
and the programming of equipment that would make the illegal tenant a completely useless player.
(1) Lacking also indicators that reflect the sustainability of Tunisian cities– the rising of insecurity, the
inaccessibility to sports, cultural and entertainment facilities, the low proportion of green areas and
playgrounds for kids, the traffic problems that include lack of parking zone.

The positive development that took place in Tunisia is the start of the ‘decentralisation’ process and
the participatory democracy that came with it, however it will time and resources to repair the
consequences of the ill designed urbanisation policies


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Copyright Lotfi Kaabi PhD –
(2) SDG12 – Responsible Consumption and Production

Tunisia (and Africa) Indicators EU Indicators

Decoupling environmental
impacts from economic growth
-Consumption of toxic
-Resource productivity
-Average CO2 emissions per km
from new passenger cars
-Energy productivity

Energy consumption
-Primary energy consumption --
-Final energy consumption
-Share of renewable energy in
gross final energy consumption
Waste generation and
-Circular material use rate
-Generation of waste excluding
major mineral wastes
-Recycling rate of waste
excluding major mineral waste
This SDG 12 is over rated

On the consumption side: (1) there is very low awareness of the public on responsible consumption,
recycling at upstream is absent and the produced household waste are skyrocketing. (1) (2) The
consumption of certified organic products is inaccessible to the average Tunisian. (3) The general
trend in the country is towards a consuming society, with a negative trade balance due to the
excessive import of consumer goods. In fact, the state is currently borrowing money to fund such
imports rather than to fix a broken economy

On the production side, (1) the permaculture practice in agriculture is inexistent as the agricultural
policy continues to favour the monoculture. (2) The use of GMO is gaining ground thanks to the lack
of legal framework and despite the ratification of Tunisia of Cartagena protocol relative to
biodiversity.(2) (3) Extractive companies whether public ones such as Compagnie Générale des
Phosphates (CPG) or private ones such as Petrofac are irresponsible producers and are behind the
worst ecological disasters in the country (3)


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Copyright Lotfi Kaabi PhD –
SDG13 – Climate Action

Tunisia (and Africa) Indicators EU Indicators

Climate mitigation
-Greenhouse gas emissions
-Greenhouse gas emissions
intensity of energy consumption

Energy consumption
-Share of renewable energy in
gross final energy consumption
-Average CO2 emissions per km
from new passenger cars

Climate impacts
-Mean near surface temperature
-Climate-related economic losses
-Mean ocean acidity

Support to climate action

-Contribution to the international
100bn USD commitment on
climate-related expending
-Population covered by the
Covenant of Mayors for Climate
and Energy signatories
The high SDG score is misleading

Tunisia is struggling to cope with the problems of desertification, water scarcity (by 2030, freshwater
resources will decrease by 28%, over ground water by 50% and the agriculture production by 52% )
and the degradation of natural resources. (1) Therefore, the limited carbon footprint indicator must
not hide the high risks of climate change and the unpreparedness of the country to face them. While,
the 2013 constitution integrated the right of future generations in clean and safe environment and
the government has published the Intended Nationally Determined Contributions (INDC) for a
reduction in greenhouse gas emissions (2), there are few real actions on the ground that lead to
believe a substantial change in the public policy to tackle the issue of climate change, and little has
been achieved from the long list of items promised to be accomplished by the government in 2015
(3) The political instability comes as a first reason – each new government has its own set of priorities
and there were 2 governments since 2015. Second comes the difficulty to raise funds to turn the
items into actions – the government put the figure to achieving SDG13 at 17.5 Billion USD (3), that’s
1.16 Billion per year – Up until 2018, the Government was supposed to have invested 3,5 Billion USD
in climate action which was not done and couldn’t be done anyway due to the squeeze in state
budget and ‘more pressing issues’. The result of missing on the plan is being felt and the government
seems helpless and unable to cope with events linked to climate change such as flush floods, hydric
stress, desertification, etc.

We recommend to include the following indicators: progress in setting adequate legislative

framework, progress in INDC implementation, allocated budget of climate action per capita, ..


24- SDGAIA Draft Concept paper, V. 1.0, April 2019

Copyright Lotfi Kaabi PhD –
SDG14 - Life below water

Tunisia (and Africa) Indicators EU Indicators

Marine conservation
-Surface of marine sites
designated under Natura

Sustainable fisheries
-Estimated trends in fish
stock biomass
-Assessed fish stocks
exceeding fishing mortality
at maximum sustainable
yield (FMSY)

Ocean health
-Seawater bathing sites with
excellent water quality
-Mean ocean acidity

SDG score is misleading as it doesn’t show the negative trend

As stated above, the recklessness of public policies related to pollution has impacted negatively over
the last decades many coastal areas such bays of Monastir, Gabes and Sfax where the maritime
biodiversity continues to decline.

- The reaction of the state after almost half a century of land and maritime pollution by the
Groupe Chimique Tunisien (CGT) is similar to that of the ostrich. (1)
- The low quality of tap water led to the booming of the bottled water industry, which
consequently increased the spill of plastic in sea and land killing biodiversity in both habitat
- The corruption in the extractive industries led to tolerating the activities of big polluters such
as the gas producing company Petrofac in total impunity ; the state even stood by it against
the latest social movements that decried the pollution done to Kerkennah Islands

Not only the state is to blame, it’s also the public and its addiction to bad habits. For instance, the
state legislation against the use of plastic bags in the supermarkets gave birth to a black market of
plastic bags (2)


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Copyright Lotfi Kaabi PhD –
SDG15 – Life on Land

Tunisia (and Africa) Indicators EU Indicators

Ecosystems status
-Share of forest area
-Biochemical oxygen demand in
-Nitrate in groundwater
-Phosphate in rivers

Land degradation
-Artificial land cover per capita
-Estimated soil erosion by water

-Surface of terrestrial sites
designated under Natura 2000
-Common bird index
Grassland butterfly index

SDG Score is misleading

While the indicator ‘Percentage change un forest area’ is green, data from the ground is damning –
Since 2011, 300,000 trees were destroyed by smugglers to make coal (1)

Unfortunately, not only smugglers take part in the deforestation, the state is also an active
stakeholder: In November 2017, the Ministry of Public Works published a call for tenders for the
construction of an Expressway linking the northern and southern suburbs of Tunis, route of this new
road provides for the deforestation of 15 thousand trees of the forest of Radès for a total area of 30
hectares (2)

Imported bio-diversity threats

The import of OGM seeds has increased since 2011 and gained speed under the current government.
Despite its ratification of Cartagena protocols on the risk prevention of modern biotechnologies,
including trans geneses, Tunisia doesn’t have till today any legislation to enforce this protocol (3), it’s
worth mentioning here that the current Tunisian Prime Minister who’s also US citizen, worked
previously as an OGM expert at the USDA’ Food Agricultural Service (4)


26- SDGAIA Draft Concept paper, V. 1.0, April 2019

Copyright Lotfi Kaabi PhD –
SDG16 – Peace, Justice and Strong Institutions

Tunisia (and Africa) Indicators EU Indicators

Peace and personal security
-Death rate due to homicide
-Population reporting
occurrence of crime,
violence or vandalism in
their area
-Physical and sexual violence
to women experienced
within 12 months prior to
the interview

Access to justice
-General government total
expenditure on law courts
-Perceived independence of
the justice system

Trust in institutions
-Corruption Perceptions
-Population with confidence
in EU institutions

The SDG 16 score is misleading

This is a catch-all SDG and yet, without it, achieving the rest of SDG would be uncertain. This SDG is
about democracy and rule of law and yet, none of the indicators mentions them, instead of human
rights, we find ‘property rights’.

Public sector accountability and transparency indicator that rates 74.5% is surrealistic – In fact,
corruption in Tunisia is ramping and the situation is so bad that the EU included the country in the
black list of countries exposed to money laundering and financing of terrorism. (1)

In 2017, Corruption in the procurement process cost the state 2 Billion TND (680 Million USD), which
is enough to build 500 Km of freeway, 3 airports and 7 colleges

On the other hand, and despite the ‘open data’ policies followed by the government, we can notice
that the opacity of some sectors remain red lines. The state continues to refuse the publication of
some data such as energy and extractives contracts, impact on the environment reports, etc. (2)


27- SDGAIA Draft Concept paper, V. 1.0, April 2019

Copyright Lotfi Kaabi PhD –
SDG17 – Partnerships for the Goals

Tunisia (and Africa) Indicators EU Indicators

Global partnership
-Official development
assistance as share of gross
national income
-EU financing to developing
-EU Imports from developing

Financial governance within

the EU
-General government gross
-Shares of environmental
and labour taxes in total tax

While there’s an emphasis on foreign partners (visa requirement score), the set of indicators
discounts the strengths and advantages brought by CSOs and the citizens who are the beneficiaries
of the SDGs. The Government needs the involvement of all local stakeholders if it’s committed to
the “localisation” of these goals as it states. While national and local governments hold primary
responsibility for delivering services, the private sector, communities and CSOs also play key roles in
shaping demand, contributing and shaping state policies and delivering services, this is particularly
relevant in areas where the government lacks capacity, or the will, to provide essential services for
the citizens. Given the scope and expectations of the SDGs, it is clear that governments alone cannot
achieve the agenda 2030.

To move forward on achieving greater impact, all facets of society have to be included in planning,
execution, monitoring and evaluation of government programmes. It is not enough to only hold
consultations with CSOs and NGOs when planning as the Government of Tunisia does often, but also
to see them as partners in implementation, monitoring progress and evaluation of outcomes.

In order to promote citizens’ ownership of the SDGs for a wider spread of their benefits.
- At all levels of government there should be institutional spaces that facilitate meaningful CSO
participation with the aim of ensuring that SDGs-related decisions can be adequately made
starting from an early stage and through implementation of participatory partnership
programmes. This will enable demand of accountability from both government and other
partners through joint reviews. This mechanism will ensure everyone plays their role
according to plan.
- Local governments should partner with CSOs to achieve localisation of the SDGs.
- Localising the SDGs must reflect regional realities, which may involve resource mobilisation
at the local level to address local problems. This does not only relate to financial
resources. There are human, material and technical resources for addressing local problems
that need to be appreciated, mobilised and utilised.

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Copyright Lotfi Kaabi PhD –
Annex 2-

Basic Principles for the Data Revolution for Sustainable Development

The data revolution will need to be harnessed for sustainable and inclusive development through
proactive measures and guided by the following KEY PRINCIPLES:


Poor quality data can mislead. The entire process of data design, collection, analysis and
dissemination needs to be demonstrably of high quality and integrity. Clear standards need to be
developed to safeguard quality, drawing on the UN Fundamental Principles of Official Statistics and
the work of independent third parties. A robust framework for quality assurance is required,
particularly for official data. This includes internal systems as well as periodic audits by professional
and independent third parties. Existing tools for improving the quality of statistical data should be
used and strengthened, and data should be classified using commonly agreed criteria and quality

No one should be invisible. To the extent possible and with due safeguards for individual privacy and
data quality, data should be disaggregated across many dimensions, such as geography, wealth,
disability, sex and age. Disaggregated data should be collected on other dimensions based on their
relevance to the program, policy or other matter under consideration, for example, ethnicity,
migrant status, marital status, HIV status, sexual orientation and gender identity, with due
protections for privacy and human rights. Disaggregated data can provide a better comparative
picture of what works, and help inform and promote evidence based policy making at every level.

Data delayed is data denied. Standards should be tightened and technology leveraged to reduce the
time between the design of data collection and the publication of data. The value of data produced
can be enhanced by ensuring there is a steady flow of high-quality and timely data from national,
international, private big data sources, and digital data generated by people. The data cycle must
match the decision cycle.


many publicly-funded datasets, as well as data on public spending and budgets, are not available to
other ministries or to the general public. All data on public matters and/ or funded by public funds,
including those data produced by the private sector, should be made public and “open by default”,
with narrow exemptions for genuine security or privacy concerns. It needs to be both technically
open (i.e., available in a machine-readable standard format so that it can be retrieved and
meaningfully processed by a computer application) and legally open (i.e., explicitly licensed in a way
that permits commercial and non-commercial use and re-use without restrictions). The underlying
data design and sampling, methods, tools and datasets should be explained and published alongside
findings to enable greater scrutiny, understanding and independent analysis.


Too often data is presented in ways that cannot be understood by most people. The data

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architecture should therefore place great emphasis on user-centred design and user friendly
interfaces. Communities of “information intermediaries” should be fostered to develop new tools
that can translate raw data into information for a broader constituency of non-technical potential
users and enable citizens and other data users to provide feedback.


As more data becomes available in disaggregated forms and data-silos become more integrated,
privacy issues are increasingly a concern about what data is collected and how it is used. Further risk
arises where collectors of big data do not have sufficient protection from demands from State bodies
or interference from hackers. Clear international norms and robust national policy and legal
frameworks need to be developed that regulate opt-in and opt-out, data mining, use, re-use for
other purpose, transfer and dissemination. They should enable citizens to better understand and
control their own data, and protect data producers from demands of governments and attacks by
hackers, while still allowing for rich innovation in re-use of data for the public good. Within the
agreed privacy constraints, people’s rights to freedom of expression using data should be protected.
People who correctly provide, collect, curate and analyse data need freedom to operate and
protection from recrimination.


Many national statistical offices lack sufficient capacity and funding, and remain vulnerable to
political and interest group influence (including by donors). Data quality should be protected and
improved by strengthening NSOs, and ensuring they are functionally autonomous, independent of
sector ministries and political influence. Their transparency and accountability should be improved,
including their direct communication with the public they serve. This can include independent
monitoring of the same public services, for example, or monitoring of related indicators such as
public satisfaction with services.


There is a global responsibility to ensure that all countries have an effective national statistical
system, capable of producing high-quality statistics in line with global standards and expectations.
This requires investments in human capital, new technology, infrastructure, geospatial data and
management systems in both governmental and independent systems, as well as information
intermediaries. At the same time, national capacity for data science must be developed to leverage
opportunities in big data, to complement high-quality official statistics. Increased domestic resources
and international support for developing countries are needed to have the data revolution contribute
to sustainable development. Applications of big data for the public good must be developed and
scaled up transparently, demonstrating full compliance with applicable laws.

Human rights cut across many issues related to the data revolution. These rights include but are not
limited to the right to be counted, the right to an identity, the right to privacy and to ownership of
personal data, the right to due process (for example when data is used as evidence in proceedings, or
in administrative decisions), freedom of expression, the right to participation, the right to non-
discrimination and equality, and principles of consent. Any legal or regulatory mechanisms, or
networks or partnerships, set up to mobilise the data revolution for sustainable development should
have the protection of human rights as a core part of their activities, specify who is responsible for
upholding those rights, and should support the protection, respect and fulfilment of human rights.

30- SDGAIA Draft Concept paper, V. 1.0, April 2019

Copyright Lotfi Kaabi PhD –