Reasons for Reform Cited

16 March 2009

        The World Bank March 13 announced plans to review its disclosure policy, unveiling an “Approach Paper” that moves in the direction of more transparency.

         Significantly, the Bank’s proposal includes a “paradigm shift,” meaning that the “presumption of disclosure” will be judged against a set of exemptions.  This approach has long been advocated by transparency activists, including the Global Transparency Initiative.

         The Bank invited public comment on the approach paper and said it plans to conduct meetings in 30 locations worldwide.

        “Under the proposed approach, more types of information would become available,” according to an accompanying “question and answer” paper.  In specific, the Bank mentions: “Quarterly Management Reports, Implementation Status and Results report (excluding staff comments), Country Portfolio and Performance Reviews, and aide memoires.  The Bank’s list of new disclosures continues with the inclusion of Country Procurement Assessments and County Financial Accountability Assessments.

        In addition, the Bank says there will be “greater transparency” for documents prepared by the staff for review by the board and its committees.  One likely issue during the comment period will be the timing of such disclosures.  Many Bank observers have said that disclosure after board meetings fails to provide the public an opportunity to comment.

       Critics have also asked for advance disclosure of more information about proposed projects, a request that does not appear to have been met in the approach paper.

Reasons for Reform Cited

The approach paper, 21 pages long without attachments, stresses the importance the Bank lays on transparency, but observes, “Both within and outside the Bank, many feel that the Bank’s disclosure policy framework still does not go far enough.” 

The existing disclosure rules, adopted in 1993 with major amendments in 2001 and some changes in 2005, relies too heavily on the so-called “positive list,”  the approach paper states. Materials not on the positive list have generally not been disclosable, and here have been no standards against which to test requests for their disclosure. 

“The policy is also not clear about what cannot be disclosed, and there are many ambiguous and overlapping rules that are cumbersome and difficult for Bank staff to implement, and for the public to understand,” according to the approach paper.

Changing the ‘Architecture’

Four principles are listed as guiding what the Bank paper says are “fundamental changes to the overall policy architecture.”

The first is “maximizing access to information,” and the second is a “clear list of ‘exceptions’ that is easier to interpret and implement.”

“The Bank would deny access only to information for which there is a compelling reasons for confidentiality – for example, personal information about staff, confidential and sensitive information given to the Bank by member countries and other third parties with the express understanding that it will not be disclosed (including proprietary information).”  Public comment is likely to center on the scope of these exceptions, which are not spelled out in the detailed way that they eventually would be in the formal disclosure policy.

Principle Three is “a clear framework for processing requests for information” and the fourth principle is “the right to appeal,” something lacking in the current system. The proposal contemplates an internal appeals mechanism, not the independent body urged by the Global Transparency Initiative, which has promoted a set of principles for transparency at international financial institutions.

Board Sets Up Task Force on Board Disclosure

The approach paper indicates that a key committee of the Bank’s board has set up a special “task force” to determine which categories of board records should be kept confidential under the new approach. These recommendations will be incorporated into the eventually “policy review paper” proposal that would be submitted for board consideration, probably for later this year.  That paper would made public for four weeks in advance of board consideration, according to the Bank’s description of the process.

However, the lack of clarity on potential board disclosure leaves a gap in the consultation process.

At present, the board issues its proposed agendas and limited, formal minutes, but does not disclose summaries of its meetings, even though they do not mention specific directors.

This and other weaknesses in the current regime are summarized in a recent GTI posting by Bruce Jenkins of the Bank Information Center, a Washington-based watchdog organization.

The approach paper outlines a classification scheme that would govern the handling of documents sent to the board.  The criteria for classification, for example as “confidential,” are not spelled out, however.

Exceptions to Disclosure Included

Notwithstanding the promise of a presumption of disclosure unless constrained by various exemptions, the approach paper in various places indicates that some specific materials should not be disclosed.

For example, within a section on the importance of preserving candor in discussions with member countries, the approach paper excludes “aide-memoire prepared following ban-Fund financial sector assessments under the Financial Sector Assessment Program.”  A footnote states further that the Bank’s management “will define the set of final decisions and documents that will be disclosed at key milestones of project preparation and implementation.”

Audit reports prepared by the Internal Audit Department are excluded, as are “analyses of creditworthiness, credit ratings, or risk.”

The approach paper also opens the door to a discussion of how older materials are handled, with the options of a 20-year declassification period or a “tiered” structure being outlined.

By Toby McIntosh

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Filed under: IFTI Watch


In this column, Washington, D.C.-based journalist Toby J. McIntosh reports on the latest developments in information disclosure in International Financial and Trade Institutions (IFTI).
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