Toolkit Issue 3, Section 2

20 November 2003

II. Policy Compliance: The Quality Assurance Compliance Unit

Since the safeguard policies have been adopted, the World Bank has undertaken periodic reviews of some of them to study whether and how well the policies are being implemented by Bank staff. One comprehensive review, "World Bank Operational Policies: Lessons of Experience and Future Directions" which was done by the Operations Policy and Strategy department in 1997, found the following:

"Given the large number of policies and procedures included in the [Operations] Manual, it has not been possible to assess the quality of compliance with any precision. The best we can say is that the quality of compliance is highly variable . . . It appears that the quality of compliance is relatively better in the areas where much of the external scrutiny-and criticism-of the Bank has been concentrated (for example environmental assessment), while it is less so in some traditional areas of accountability (for example, financial management). This reflects the important role of external disclosure and monitoring in enhancing Bank accountability and performance."

Even with the presence of external "watchdogs," Bank policy implementation can be extremely uneven. The Bank's Operations Evaluation Department reviewed implementation of the Environmental Assessment Policy and found that "The EA process is not living up to its full potential to influence project design because EAs are often completed too late in the project cycle," and that, "implementation on the ground has not adequately integrated EA recommendations and mitigation plans, and related Bank supervision has been weak." [Note:6,7]

In 1998, one of the more significant institutional changes made to address the issue of staff accountability has been the creation of a Quality Assurance and Compliance Unit. The Compliance Unit establishes a team that will review a handful of Bank projects to determine the level of compliance with the Bank's safeguard policies. If an audit detects non-compliance with a safeguard policy, prompt resolution by the Bank's regional team will be required, including the possibility of sanctions [Note:8].

The team consists of internal experts from fields like resettlement, indigenous peoples and environmental assessment and is run by the Environment and Socially Sustainable Development Department (ESSD). The Unit also intends to establish a point person in each region who would review the overall compliance of the region to the ten safeguard policies. Those people have not yet been chosen.

In order to facilitate the work of the Compliance Unit, starting in July 1999, Project Concept Documents will contain information about the safeguard policies which are expected to be invoked in each project. Other internal Bank documents will also include information pertaining to compliance of each safeguard policy. A decision to audit will be based on the following criteria:

• Entry onto the Bank's own "Acute List," a list which the Bank generates when projects are not likely to succeed;
• When there is an internal disagreement over the environmental categorization of a project;
• When NGOs report problems; and
• Random selection from among the Bank's Category A or B projects [Note:9].
  

NGOs thus have the option to promote an audit by bringing specific problem projects, or projects that they feel have been mis-categorized, to the attention of the Compliance Unit, the ESSD Vice President, or to a Regional Vice President. An audit is an internal Bank procedure so NGOs should not expect to see the results of this work. (The Bank has refused to make the results of its audits public.) Nor should NGOs consider an audit as a substitute for bringing a claim through the Inspection Panel to the World Bank. The Compliance Unit is simply a tool which allows the Bank to address non-compliance problems brought to its attention by NGOs and others. The Bank hopes that with this mechanism it can avoid further Inspection Panel claims and bring staff into better compliance with safeguard policies.

NOTES:

6. For more information about the Environmental Assessment Policy, see the Toolkit The World Bank's Environmental Assessment Policy.

7. "Effectiveness of Environmental Assessments and National Environmental Action Plans: A Process Study"; the World Bank Operations Evaluation Department (June 28, 1996).

8. Internal World Bank memo, April 1998.

9. Category A Projects are those with significant, unprecedented or irreparable environmental impacts, and Category B Projects are those with limited or specific environmental impacts

This toolkit was prepared by Kay Treakle as part of the Bank Information Center's Toolkits for Activists: A User's Guide to the Multilateral Development Banks. The Bank Information Center (BIC) is an independent non-profit, non-governmental organization that provides information and strategic support to NGOs and social movements throughout the world on the projects, policies and practices of the Multilateral Development Banks (MDBs). BIC advocates for greater transparency, accountability and citizen participation at the MDBs. BIC is supported by private foundations and organizations that work in the fields of environment and development, and is not affiliated with any of the MDBs.