[asia-apec 1686] Global Call for Greater Transparency at the World Bank

[Kevin Yuk-shing Li]

http://www.bicusa.org/action/sign/index.htm

The World Bank is in the process of reviewing its Policy on Information 
Disclosure and has begun consulting civil society on the proposed 
changes. The information policy is relevant to almost every aspect of 
every area in which the World Bank works. Whether your interest is a 
particular project that is affecting a given community or policy issues 
related to the environment, gender or macro-economics, you cannot 
participate without information.

The Bank's information policy also has significance far beyond its own 
work. Greater openness at the Bank will influence the practices of other 
international agencies and governments. Even if you do not work directly 
on World Bank issues, greater transparency is in the general interest of 
all those who advocate for open and participatory decision-making and 
institutions.

Unfortunately, the changes that the Bank is proposing to the information 
policy are very modest and do not go far enough in addressing the urgent 
need for greater transparency and participation. Significant pressure 
from organizations around the world will be needed in order to improve 
the policy. It is particularly important that people sign the "Global 
Call for Greater Transparency at the World Bank".

While there are a number of organizations around the world that are 
working on this issue, if you would like to Endorse the Global Call, or 
would like further information from the Bank Information Center, please 
contact Graham Saul (gsaul at bicusa.org - fax: 202-737-1155 or by phone 
202-624-0626). Graham will be happy to answer any questions that you 
have. You can also find more information on our website at: www.bicusa.org

I look forward to hearing from you,

Graham Saul

********************************************************

To endorse the following letter, send an email or fax to Graham Saul at 
the Bank Information Center - gsaul at bicusa.org , Fax: 202-737-1155. 
Please include your name, organization and country.

http://www.bicusa.org/action/sign/index.htm

Global Call for Greater Transparency at the World Bank


Ms. Joanne Salop
Vice President
Operations Policy
1818 H Street N.W.
Washington D.C. 20008

Dear Ms. Salop,

We are writing to express our support for transparency in the largest 
development institution in the world and to express our concerns about 
the World Bank's proposed information disclosure policy. The World Bank? 
increasing emphasis on participation and ?wnership?in the past few 
years is a welcome acknowledgement of the central role that development 
must accord to the very people whose economic lives are to be developed. 
We believe that the Bank? information policy must reflect commitment to 
and trust in the principles and promises of full popular participation.

A fundamental norm of participation, partnership and ownership is consent 
of the partners and those invited to participate. Consent is meaningless 
unless it is informed. At the World Bank, the information disclosure 
policy is the single most effective enabler toward development 
effectiveness and partnership goals. We believe there is a direct 
relationship between the implementation of the information disclosure 
policy and the ability and willingness of the public to be engaged in 
Bank activities.  Furthermore, the information disclosure policy has 
allowed interested members of the public to monitor the outcomes of 
specific investments and has in part helped to assure that benefits reach 
the intended beneficiaries.

In this new century, and with the accelerated pace of globalization the 
IDA Deputies and the G7 have recognized the need for more transparency at 
the international level. While it was not entirely voluntary, the Bank is 
to be commended for taking a first step toward transparency at the 
international level through this review of the 1993 information 
disclosure policy. With modern technology and an accelerated pace of 
change affecting even the most remote communities, information is one of 
the very few tools available to the poor and the public at large that 
allows civil society to both understand and prepare for 
change.  Transparency is an empowerment tool for the poor.

The draft information disclosure policy moves toward greater disclosure 
and as such is welcomed.  There are, however, crippling limitations to 
the policy that must be addressed if the Bank is to foster an inclusive 
development model and achieve greater development effectiveness. In its 
current form, the policy falls far short of enabling partnership and 
participation. Whole categories of important information continue to be 
withheld from the public, including all information pertaining to 
structural adjustment and sectoral adjustment loans  the lending that 
currently makes up the bulk of the Bank? portfolio. Disappointingly, 
within the policy it appears that the Board of Executive Directors is not 
prepared to embrace basic good governance practices that begin with 
information disclosure. With this letter we argue for the release of:
?      all Country Assistance Strategies;
?      the President? Report, Tranche Release Memorandum and project 
documentation relating to structural adjustment and sectoral adjustment;
?      aide memoires, project status reports, policy papers and country 
policy and institutional assessments;
?      Board Minutes or the summaries of Board discussions that relate 
to project and adjustment lending.

Limitations in the New Policy

The World Bank continues to withhold some Country Assistance Strategies 
from the public even though the public is increasingly asked both to 
participate in the development of this strategy and work with the Bank in 
its implementation. The inconsistency in this process should be 
rectified. Development is not an exclusive process, but requires multiple 
stakeholders to be engaged in order to be successful. The World Bank 
cannot expect support from donors, the poor, other development agencies 
or even broad borrowing country governmental support if its basic 
strategy for development success is not made known to the public. 
Currently there are two sets of standards: an open and transparent 
standard for poor countries and a closed and secret standard for middle 
income countries. We are aware of the concerns expressed by many 
countries regarding the availability of the CAS. The CAS, however, 
according to your own website, is a Bank owned document.  As such, it is 
both the right and the responsibility of the World Bank to disclose this 
document.  Failure to disclose the overall plan for the Bank's operations 
in any given country mocks the presumption in favor of disclosure that 
underpins the information disclosure policy.

Macroeconomic Information

We are deeply disappointed by the lack of progress on disclosing 
documents relating to structural adjustment lending. The current proposal 
will simply affirm existing practice of allowing a country to make 
information available at its own discretion.

In Fiscal Year 1999, 63% of the World Bank? lending operations consisted 
of policy-based lending (such as structural or sectoral adjustment 
lending). No documentation has been made available to illuminate the 
goals, the implementation or the outcomes of these loans. Under the 
proposed information policy the public will continue to be effectively 
excluded from participation in the bulk of the World Bank? lending 
operations. Popular participation is increasingly seen as an effective 
way in which to foster ownership within a borrowing country. Without the 
basic documentation, citizens cannot be expected to participate in the 
development, implementation or monitoring of these lending operations.

Structural adjustment is viewed as one of the key ways in which the World 
Bank is engaged in globalization  a contested issue that has sparked 
massive protests around the world. The failure to release material 
related to structural adjustment will impede the public? understanding 
of the Bank and fosters suspicion around the Bank's role in 
globalization. While the Bank has attempted to rectify the lack of 
openness on SAPs with a consultative process for the creation of the 
Poverty Reduction Strategy Paper (PRSP), the two remain quite different 
instruments. One is a broad planning instrument and the other is an 
actual loan. Without access to the loan process it remains impossible for 
the public to track the implementation of the broad policy goals outlined 
in the PRSP.

SAPs are often negotiated in a very narrow discussion that excludes 
relevant ministries and parliamentarians. Nevertheless, parliaments are 
often asked to approve the loans without access to the basic 
documentation and ministries are expected to implement the loans. In 
1999, in Brazil, the parliament could only obtain a leaked copy of 
important information around specific proposed investments. Public 
decisions undertaken in the absence of full information often fail in the 
implementation stage in large part because the goals are not fully agreed 
upon or well understood. The development effectiveness would be greatly 
enhanced by public debate and broad governmental participation.  In order 
to increase development effectiveness the President? report, tranche 
release memorandum and project documentation relating to structural 
adjustment and sectoral adjustment loans should be released. The 
half-step outlined in the draft policy would only codify what is now 
existing practice.  More importantly, the proposal blurs the line of 
responsibility between Bank and Borrower. It places the onus on the 
borrower to both take a decision about Bank generated documents and to 
undertake the responsibility for distribution. Again in the case of 
macroeconomic information, the Bank has made a proposal that is not in 
line with the presumption in favor of disclosure.

Fostering Participation

Perhaps the most disappointing aspect of the proposed new policy is the 
argument that many documents cannot be released because disclosure would 
impede 'the deliberative process.' This argument is unsubstantiated 
within the policy and contradicts the Bank's espoused goals of 
participation and partnership.  Neither goal can be achieved without 
timely information disclosure. Disclosure after a decision has been taken 
does not foster ownership and cannot be expected to satisfy public 
demands to participate in development decisions. Meaningful 
"participation" requires access to documents while they are still 
relevant to the "deliberative process," not AFTER final decisions are made.

The Bank should release aide memoires, project status reports, policy 
papers and country policy and institutional assessments precisely because 
they inform the deliberative process.

In its new policy the Bank argues that draft project appraisal documents 
(PADs) do not need to be released because relevant information is already 
available through the project information documents (PIDs). This argument 
does not stand up under close scrutiny. Draft PADs include detailed 
information that is normally not included in PIDs such as:  the results 
of public consultation (in Category A projects), key performance 
indicators, project alternatives that have been considered, the value 
added of Bank support, the effectiveness conditions, technical 
information such as maps that actually lay out the proposed affected 
area, and a list of other technical documents produced for the project. 
Effective stakeholder participation in the project cycle requires that 
the Bank either release Draft PADs or radically improve and more 
regularly update the composition of PIDs.

The policy also fails to address the issue of getting 
information  especially project information into the hands of 
directly  affected people. In particular, the policy does not address the 
issue of translating key documents, including the safeguard policies. The 
fact that the draft policy identifies ?xcessive cost or logistics?as a 
reason for non-disclosure is troubling because it appears to provide an 
excuse for not getting information into the hands of the most directly 
concerned.

Governance and the Board

Over the past two years in response to shareholder and public concerns 
about quality and compliance issues the Bank has created two instruments 
to help improve both the quality of loans and the compliance rates with 
safeguard policies. These are the Quality Assurance Group and the Quality 
and Compliance Unit. The new policy notes that the materials generated 
from these review units will not be made available to the Board or the 
public. The very idea that the findings of units that have been 
established in direct response to shareholder and stakeholder demands are 
not to be disclosed to the Board or other stakeholders is disturbing. In 
the new policy, no rationale is given for the non-disclosure of QAG's 
periodic synthesis reports. There is no excuse for the Bank not to 
disclose this information.

The findings of these units could be very helpful to the Board in its 
oversight role as they pinpoint problems in specific investments and in 
broader areas like monitoring and supervision. Through the Inspection 
Panel process the Board increasingly is confronted with problems that are 
also identified through the QAG and QACU. Early Board awareness could 
lead to more timely solutions and an avoidance of Inspection claims. If 
these materials were to be released to the public it would also help to 
improve development effectiveness. The Operations Evaluations Department 
and your own team have on separate occasions noted that the public 
spotlight has already proven to be one of the best incentives to persuade 
Bank personnel to administer projects more effectively.

Lastly, we are very concerned about the Board? lack of transparency. The 
World Bank has determined that good governance is an important component 
for development effectiveness. One of the defining criteria of good 
governance is transparency. It is ironic that the Board of Executive 
Directors would approve a condition for borrowing country governments 
that it is not willing to embrace in its own operations, i.e. that of 
transparency. Transparency in the Board would be enhanced by the 
disclosure of Board Minutes or the summaries of Board discussions that 
relate to project and adjustment lending, along with the proposed 
Chairman? Summaries.  It is contradictory for the Board to require and 
encourage borrowing countries to govern in the sunshine when it continues 
to labor in the dark.

We appreciate the opportunity to share our view with you.  We look 
forward to a revised policy that fosters transparency and empowerment for 
the poor.


To endorse this letter, send an email or fax to Graham Saul at the Bank 
Information Center - gsaul at bicusa.org , Fax: 202-737-1155. Please 
include your name, organization and country.

Graham Saul
Bank Information Center
733 15th Street NW
Suite 1126
Washington, D.C.  20005
USA
www.bicusa.org

phone: (202) 624-0626
fax: (202) 737-1155
e-mail: gsaul at bicusa.org