Accountability Counsel and Partners Call for Greater Transparency and Stakeholder Engagement in the IFC/MIGA Accountability Framework Review Process

Yesterday, Accountability Counsel and 74 global partners submitted a joint statement to the World Bank Group's Board of Directors, expressing concerns about the lack of transparency and external stakeholder engagement in the accountability framework review of the International Finance Corporation (IFC) and Multilateral Investment Guarantee Agency (MIGA). This process includes a review of IFC/MIGA's independent accountability mechanism (IAM), the Compliance Advisor/Ombudsman (CAO). Recognizing the importance of a strong accountability framework and IAM to address community concerns and facilitate institutional learning, we and partners are calling for a review process that is robust, transparent, and inclusive of stakeholder voices.Read our full statement below.October 23, 2019Via Electronic Mail

Lack of Transparency and Adequate External Stakeholder Participation in the IFC/MIGA Accountability Framework Review Process

As organizations that support communities adversely affected by internationally financed projects, including World Bank Group projects, we are writing to comment on the accountability framework review of the International Finance Corporation (IFC) and Multilateral Investment Guarantee Agency (MIGA), which includes a review of their independent accountability mechanism (IAM), the Compliance Advisor/Ombudsman (CAO). Recognizing the importance of a strong accountability framework and IAM to address community concerns and facilitate institutional learning, this review process must be robust, transparent, and inclusive of stakeholder voices.The review of IFC/MIGA’s accountability framework should be informed by the people who use it – the individuals and communities who have been affected by IFC/MIGA-supported projects and the civil society organizations (CSOs) who support them. Especially given the significance and far-reaching implications of this review, there should be a robust consultation process and public disclosure of relevant documents. Unfortunately, to date, neither seem to be envisioned. We ask the Board to ensure that the upcoming review is transparent, meaningful, and inclusive, by:

• Extending the timeline of the review to allow for a more robust process;
• Publicly disclosing the full Terms of Reference (TOR) and other documents pertaining to the review, including relevant timelines;
• Including adequate opportunity for feedback and equipping the Review Team with robust means of collecting and reviewing comments;
• Providing communities with the opportunity to weigh in using their own language;
• Including several opportunities for in-person consultation and holding outreach meetings to solicit input not just from CSOs but also local communities and past complainants; and
• Publishing the Review Team’s report and recommendations prior to a Board decision on changes to the accountability framework.

First, we understand that this review process will take place over a relatively short period of time. The Board should reconsider this timeline to ensure that the review is legitimate and robust, incorporating the recommendations outlined above.Second, we are deeply disturbed that the full TOR and other documents relevant to the review process have not been disclosed. Some of the signatories to this letter participated in a brief introductory meeting with the Review Team tasked with examining and reporting on the effectiveness of the accountability framework and generating recommendations for the Board. While the participants appreciated the opportunity to meet with the team, meaningful engagement was difficult because the participants lacked information about the TOR and the issues under consideration. Moreover, although there has been subsequently a public announcement with some details of the review, it is still difficult for the broader public to know the full suite of the aspects of IFC/MIGA’s accountability framework and the CAO that are being examined. The secrecy behind the review sets a dangerous precedent with respect to transparency and hinders stakeholders’ ability to be useful to the Review Team. For stakeholders to effectively participate in this process, they must know the full parameters. The review process must not be veiled; therefore, we request that the full TOR and other documents pertaining to the review be published immediately.Third, the Review Team should have a structured means of receiving input from global communities and CSO stakeholders, and input should be gathered over a designated and broadly publicized comment period. Posting an announcement on the World Bank’s website with an email address to send feedback is not enough. Although the review of the World Bank Inspection Panel’s toolkit has been imperfect and has also suffered from a lack of transparency, it has at least incorporated two stakeholder comment periods. In addition, the Review Team should have the ability to meet with stakeholders around the world, including complainants and local communities. Not having these opportunities hinders the Review Team’s ability to understand community perspectives and experiences with IFC/MIGA and the CAO, lays the groundwork for an incomplete review, and will be a disservice to those of whom IFC/MIGA are accountable.Fourth, we gather that the Review Team currently does not have the resources to translate comments or input not submitted in English. Priority should be given to the voices of the very communities impacted by IFC/MIGA-supported projects. Not accommodating for stakeholder feedback in their own language denies whole communities a voice, and the Review Team will be deprived of essential input on the effectiveness of IFC/MIGA’s accountability framework and the CAO. Placing the burden on communities or CSOs to translate all submissions is wholly improper and an affront to the principles of stakeholder engagement.We encourage the Board and Review Team to consider practices adopted at other institutions with respect to consultation processes. As an example, the European Bank for Reconstruction and Development recently reviewed its Project Complaint Mechanism. The review included regular engagement with CSOs for over a year and a half, solicitation of detailed feedback prior to the commencement of the official review, and regularly-provided updates throughout the review process. It released translations of its draft recommendations in several languages, including Arabic, and organized eight regional, in-person consultations.Finally, we are deeply concerned that, given the lack of transparency in this process, the Review Team’s report and recommendations will not be disclosed before the Board makes a decision on updating the accountability framework and the CAO’s Operational Guidelines. Given the far-reaching implications of this review process, stakeholders must have an opportunity to see and provide feedback on the recommended changes.We appreciate that the Board is taking a hard look at improving the accountability framework, and we thank you for considering our recommendations during this important process. We look forward to ongoing engagement with the Board to ensure that accountability at IFC/MIGA is strong, for the benefit of communities around the world and IFC/MIGA.

Signatories

Abibiman Foundation – GhanaACADHOSHA – Democratic Republic of the CongoAccountability Counsel – United StatesAction For Development – ZambiaAction Paysanne Contre la Faim – Democratic Republic of the CongoAfrica Centre for Investment and Trade Policy Facilitation – UgandaAfrican Law Foundation (AFRILAW) – NigeriaArab Watch Coalition – RegionalAssociation for Women and Children’s Affairs – IraqAssociation Tunisienne pour le Droit de Development – TunisiaBank Information Center – United StatesBank Information Center Europe – The NetherlandsBoth ENDS – The NetherlandsBretton Woods Project – United KingdomBuliisa Initiative for Rural Development Organisation (BIRUDO) – UgandaCEE Bankwatch Network – RegionalCenter for International Environmental Law (CIEL) – United StatesCentre for Research on Multinational Corporations (SOMO) – The NetherlandsCentro de los Derechos del Campesino – NicaraguaCITIM (Centre d'information Tiers Monde) – LuxembourgCommunity Outreach for Development and Welfare Advocacy (CODWA) – NigeriaCommunity Policing Partners (COMPPART) – NigeriaConseil Régional des Organisations Non Gouvernementales de Développement – Democratic Republic of the CongoConseil Régional des Organisations Non Gouvernementales de Développement du KasaïOriental – Democratic Republic of the CongoCOPA-Kenya – KenyaDynamique pour la Promotion et la Protection de l'Artisanat Minier au Tchad (DYPRODAMIT) – ChadEgyptian Center for Civic and Legislative Reform – EgyptEgyptian Initiative for Personal Rights – EgyptEquitable Cambodia – Cambodiaetika asbl – LuxembourgFoundation for Environmental Management and Campaign Against Poverty – TanzaniaFoundation For Environmental Rights, Advocacy & Development (FENRAD) – NigeriaFreedom from Debt Coalition (FDC) of the Philippines – The PhilippinesFriends of the Earth Japan – JapanFriends with Environment in Development – UgandaFundación Ambiente y Recursos Naturales – ArgentinaFUNDEPS – ArgentinaGender Action – United StatesGLOBAL RIGHTS – NigeriaGreen Advocates International – LiberiaInclusive Development International – United StatesIndian Social Action Forum (INSAF) – IndiaInstitute for Agriculture and Trade Policy (IATP) – United StatesInternational Accountability Project – United States/GlobalInternational Rivers – United StatesJamaa Resource Initiatives – KenyaKebetkache Women Development & Resource Centre – NigeriaLebanese Union for Persons with Physical Disabilities (LUPD) – LebanonLebanon Eco Movement – LebanonLoeildafrique Media – TogoLumière Synergie pour le Développement – SenegalDr. Muatar Khaydarova (Independent Expert on Freedom of Association) – TajikistanNarasha Community Development Group – KenyaNatural Resources Alliance of Kenya – KenyaNature Tropicale ONG – BeninNGO Forum on ADB – RegionalObservatoire d’Etudes et d’Appui à la Responsabilité Sociale et Environnementale (OEARSE) – Democratic Republic of the CongoOxfam – GlobalOyu Tolgoi Watch – MongoliaPakistan Fisherfolk Forum – PakistanPeace Point Development Foundation – NigeriaPhenix Center for Economic and Informatics Studies – JordanProject on Organizing, Development, Education, and Research (PODER) – MexicoSEATINI UGANDA – UgandaSocial Justice Connection – CanadaStudies and Economic Media Center – YemenSUHODE Foundation – TanzaniaTunisian Association for Transparency in Energy and Mines – TunisiaUrgewald e.V. – GermanyWedian Association for Social Development – YemenWitnessradio.org-Uganda – UgandaWomanHealth Philippines – The PhilippinesYemen Observatory for Human Rights – YemenYemen Organization for Promoting Integrity – YemenYouth For Environment Education And Development Foundation (YFEED Foundation) – Nepal