BIC's is engaging on five broad issues addressed in the strategy: transparency, participation, projects, internal Bank governance and the private sector. Read BIC's January 26, 2007 comments on the strategy, which were submitted during the last consultation phase.
Following are some key points of concern for civil society groups monitoring the development of the strategy. This is by no means an exhaustive list or treatment of the issues.
Lack of transparency and public consultation
This Bank strategy is being developed through a rapid, largely confidential, internal process, particularly inappropriate considering that the fight against corruption and for government accountability must be driven by the public. Although it eventually agreed to disclose the outline of the paper, the Bank appears to be making little effort to meaningfully solicit input from interested parties around the world. The period for comment is extremely short, with very few public meetings being scheduled on short notice and in a seemingly ad-hoc manner. Furthermore, the full paper is already being drafted before the close of the comment period, suggesting a lack of intent to incorporate feedback received.
The appropriate role for the Bank
The Bank may have a particular role to play in fighting corruption and promoting good governance. However, other entities and organizations are better prepared to handle and advise many aspects of the fight. Although the Bank has voiced interest in collaborating with other actors, the strategy currently assumes an overly ambitious role for the institution. Furthermore, the Bank must not lose sight of its poverty reduction mission.
Governance and corruption
Fighting corruption is one component of good governance. Many have criticized the framework for its rough blending of the two and subsequent lack of attention to other important aspects of good governance, including national democratic processes and citizen participation. Good governance can also include issues regarding human rights; the Bank’s role in this area is highly controversial and/or unclear.
Conditionality
Debate continues over what are appropriate requirements (conditionalities) for donors to place on governments as conditions for access to aid resources. Past controversies over onerous economic and policy conditionalites are resurfacing in the context of potential governance conditionalities.
Department of Institutional Integrity (INT) Review
The Board specifically asked for an independent review of INT in the Work Plan, and it will certainly draw the attention of many monitoring the strategy. Paul Wolfowitz has increased INT’s capacity and given it a more proactive mandate since taking office. However, his appointment of controversial Republican ally Suzanne Rich Folsom to head the department has raised eyebrows.
Debt
Concerns focus on past and continued lending to corrupt regimes, establishing systems to ensure that debt relief benefits the poor, and removing conditionalities from debt relief. Countries must also address the outflow of stolen assets from developing nations. Some thorny questions arise in the discussions on debt and corruption, including whether and how the Bank should continue to engage with highly corrupt regimes.
Transparency
Transparency in both Bank and country operations is critical to fostering the demand side of good governance, and the institution must pay adequate attention to both. Many groups see the anti-corruption strategy as an opportunity to renew long-standing calls for increased transparency in project preparation and implementation.
Extractive industries
Oil, gas and mining projects are highly vulnerable to corruption and prone to poor governance, the impacts of which fall disproportionately upon the poor and the environment. Many are watching whether the Bank’s strategy will increase transparency and accountability in the sector, arguing that it should more robustly address concerns ranging from tracking budgets and revenue streams, to identification and development of projects.
Infrastructure
The Bank is increasing investments in large high-risk infrastructure projects, and has recently merged the Environment and Infrastructure Departments into a new Sustainability Network. The framework needs to aggressively address how projects are selected in problem sectors and ensure the release of supervision reports throughout project implementation.
Private sector, particularly northern companies
The responsibility of the private sector for corruption and its role in fighting corrupt practices and promoting good governance is underplayed in the current strategy. Increased focus on the role of the private sector acknowledges both the supply and the demand sides of corruption.
Whistleblower protections
The Bank is currently revising its whistleblower protection system. While not officially a part of the anti-corruption strategy, these protections are an essential component to promoting accountability inside the institution.
The details
The strategy suggests the creation of several specific new mechanisms, including anti-corruption plans and governance diagnostics. Development and consistent application of these mechanisms is a key concern.