access to information at development banks

ACCESS TO

INFORMATION AT

DEVELOPMENT

BANKSGaia Larsen Roland Widmer amp Bradley Schliesmann Photo flickr Gerardo Pesantez World Bank

INTRODUCTION

Transparency is vital for good governance and effective sustainable development Access to information is a key element of development effectiveness Information allows the public to understand the actions of their government and the financial institutions active in their country and helps people hold these actors accountable for their actions

As a result of public pressure to embrace transparency many development banks have developed policies to allow public access to information about their activities These policies aim to clarify what information is available to the public how the public can access that information and what types of information are to be kept from public access

GLOBAL DEVELOPMENT BANKS

The following global development banks are included in this slide deck

bull World Bank (WB composed of IBRD amp IDA) ndash finances public actors globally

bull International Finance Corporation (IFC) ndash finances private actors investing in developing countries

bull Multilateral Investment Guarantee Agency (MIGA) ndash provides political risk insurance guarantees to private companies investing in developing countries

Photo flickrInternational Rivers flickrLuke Mackin flickr CGIAR

DOCUMENTS REVIEWED ndash


Instit Policy Related Documents1

WBbull Policy on Disclosure and Access to

Information (2012)

bull Disclosure and Access to Information

Handbook

IFC bull Public Communications Policy (2011)

bull ADB Disclosure Handbook

bull Translation Framework

bull Safeguard Policy Statement

MIGA bull Public Information Policy (2014) bull Environmental and Social Policy

1 These documents provide further details on how the ATI policy is to be implemented

REGIONAL DEVELOPMENT BANKS

The following regional development banks are included in this slide deck

bull African Development Bank (AfDB) ndash supports public and private actors in Africa

bull Asian Development Bank (ADB) ndash supports public and private actors in Asia

bull European Bank for Reconstruction and Development (EBRD) ndash supports micro small

and medium-sized enterprises in Europe western Asia and northern Africa

bull European Investment Bank (EIB) ndash invests primarily in the poorer European countries

bull Inter-American Development Bank Group (IDB) ndash supports governments and

companies in Latin America and the Caribbean



Instit Policy Related Documents

AfDBbull Policy on Disclosure and Access to

Information (2012)


Handbook

ADB bull Public Communications Policy (2011)




EBRD bull Public Information Policy (2014) bull Environmental and Social Policy

EIB bull EIB Transparency Policy (2010)

bull Guidance Note for Promoters and

Partners on the EIBrsquos Transparency

Policy

bull EIB Statement of Environmental amp Social

Principles amp Standards

IADB bull Access to Information Policy (2010)bull Environment and Safeguards

bull Compliance Policy

NATIONAL DEVELOPMENT BANKS

These national development banks that are included in this slide deck

bull Development Bank of Southern Africa (DBSA) ndash a South African bank which supports primarily large infrastructure projects in southern Africa

bull French Agency for Development (AFD) ndash public development finance institution that fights poverty and fosters economic growth in low and middle income countries and the French Overseas Provinces

bull Overseas Private Investment Corporation (OPIC) ndash US Governmentrsquos development finance institution which mobilizes private capital to support US companies investing in developing countries



Instit PolicyLaw Related Documents

AFD

bull Transparency Policy (2007)

bull French Law on Development Policy and

International Solidarity (2014)

bull Annex to the Transparency Policy

French Law 2014-773

bull Interdepartmental Committee on

International Cooperation amp

Development (2013) Summary of

Decision

DBSA

bull DBSA Promotion of Access to

Information Act A Guide to Access

Information (2012)

bull DBSA Environmental and Social

Safeguard Standards (2014)

OPIC

bull United States Freedom of Information

Act (FOIA)

bull FOIA regulations at 22 CFR Part 706

bull Open Government Plan

bull Information Quality Guidelines

bull Environmental and Social Policy

Statement (2010)

bull FOIA FAQ


NOT REVIEWED

While some national development banks have developed access to information policies (often in reaction to legal requirements associated with their home country) other national banks still lack policies outlining the publicrsquos right to gain access to information about their activities This includes some of the worldrsquos largest development banks such as

bull Brazilrsquos National Development Bank (BNDES) and

bull China Development Bank (CDB)

Due to the lack of policies at these institutions we did not include them in this analysis

WHY

TRANSPARENCY

Photo flickrFXP

STATED INTENT OF THE ATI POLICIES

The Access to Information (ATI) policies of the development banks aim to boost institutional effectiveness in delivering development results This appears to be particularly true for the global and regional banks

bull The IFC ldquobelieves that transparency and accountability are fundamental to fulfilling its development mandaterdquo

bull The ADB policy aims to ldquo[i]ncrease the development impact of ADB operationsrdquo

bull The IDB expects that transparency will ldquoimprove the quality of its operationsrdquo

TRANSPARENCY ACCOUNTABILITY

amp LEGITIMACY

Development banks state that transparency can increase accountability

bull AfDB ldquothrough greater transparency stakeholders are able to monitor the outcomes of Bank Group operations and therefore help assure that benefits reach the intended beneficiariesrdquo

bull World Bank greater openness ldquonot only assists in exposing potential wrongdoing and corruption but also enhances the possibility that problems will be identified and addressed early onrdquo

They also state that transparency builds trust and legitimacy

bull ADB an objective of the policy ldquois to enhance stakeholdersrsquo trust in and ability to engage with ADBrdquo

bull EBRD ldquobelieves that transparency and accountability are fundamental tohellip strengthening public trust in the EBRDrdquo

bull IFC ldquowhen clients are committed to transparency and accountability they help promote the long-term profitability of their investmentsrdquo

WHAT DO THE

POLICIES

INCLUDEPhoto flickrEvgeni Sotov

PRESUMPTION IN FAVOR OF ACCESS

The ATI policies are based on certain fundamental principles One such principle is tomaximize disclosure by making all information open and available to the public unlessit falls into one of the limited and clearly defined exceptions This principle is known asthe ldquopresumption in favor of accessrdquo

Global Regional National

IFC MIGA WB AfDB ADB EBRD EIB IADB AFD DBSA OPIC

Does the policy have a presumption in favor of access

Yes Yes Yes Yes Yes Yes Yes Yes No Yes1 Yes

1 South Africarsquos Promotion of Access to Information Act provides a presumption in favor of access which legally should apply to DBSA The DBSA policy does not specifically state this however

PROACTIVE DISCLOSURE

One main way that the development banks give access to information is by providing such information regularly on their website or at information centers at their headquarters and in-country offices without people having to ask for it first

ATI policies tend to list at least some of the informationthat the banks must discloseproactively to the public which allows people to access that information without having to first submit a requestto the institution

Photo flickrMagnus Halsnes

EXAMPLES OF PROACTIVELY

DISCLOSED INFORMATION



Board meeting minutes

Yes Yes Yes Yes Yes Yes No Yes No No Yes

Board Committee meeting minutes

Yes Yes YesSome-

times1 No No No Yes No No Yes

ProjectProgram documents

Yes Yes Yes Yes YesSumm-

aries Yes Yes Yes NoSumm-

aries

Country Strategies Yes Yes Yes Yes Yes Yes Yes Yes Yes No No

Environmental amp Social Impact Assessments

Yes Yes Yes Yes YesSome-

times2 Yes Yes No No Yes

Information on how to access information

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

1 When the committee makes a decision and a subsequent Board discussion is not expected2 Environmental and Social Impact Assessments are disclosed for Category A projects summaries are disclosed for other types of projects

REQUESTS FOR INFORMATION

The development banks also provide information upon request All of the banks have sections or divisions responsible for overseeing implementation of their ATI requirements and requests for information can usually be submitted to these bodies via online forms email fax regular mail or in person

Photo flickrMeena Kadri

WHO IS RESPONSIBLE FOR

IMPLEMENTATION

GLOBAL

IFC Public Affairs

MIGA Corporate Communications Unit

WB External and Corporate Relations Archives Unit Legal Department

REGIONAL

AfDB Communication and External Relations Department (CERD)

ADB Public Information amp Disclosure Unit (InfoUnit)

EBRD Secretary General Communications Department

EIB Communications Department

IDB Office of the Secretary ndash Access to Information Section

NATIONAL

AFDStrategy Partnership and Communication Directorate ndash Strategic Steering and

Accountability Division

DBSA Information Officer (CEO) Deputy Information Officer

OPIC Office of External Affairs Office of the Chief Information Officer FOIA Office

HOW LONG DO THE BANKS HAVE TO RESPOND

GLOBAL

IFC Response in 30 days unless additional time required due to scope of request

MIGA ldquoEndeavorsrdquo to respond within 30 days unless more time is required

WBAcknowledged within 5 working days response within 20 working days Additional time may be needed

REGIONAL

AfDBAcknowledged within 5 working days more comprehensive response within 20 working days More time may be needed in some special circumstances

ADBAcknowledged within 5 working days and notification as soon as a decision has been made but no later than 20 working days

EBRDAcknowledged generally within 5 working days not more than 10 working days Normal response within 20 working days can be expanded to max 40 working days

EIB Reply ldquowithout delay no later than 15 working days

IADBResponse within 30 calendar days 45 calendar days for historic information If more time is required the public information center will inform the requester

NATIONAL

AFD Reply within 30 business days If more time required will contact requester

DBSA Will inform the requestor of his decision within 30 days may extend to max 30 days

OPICThe FOIA requires OPIC to respond within 20 working days of receipt In unusual circumstances OPIC may require an extension of time or expedite process

ARE TRANSLATIONS AVAILABLEGLOBAL

IFC IFC will respond to requests in English but if receives requests in other languages will try to respond in that language Abides by WBG Translation Framework

MIGAMIGA will respond to request in English but it receives requests in other languages will try to respond in that language Abides by WBG Translation Framework

WBOfficial languages Arabic Chinese English French Portuguese Russian and Spanish The Bank translates documents in accordance with the WBG Translation Framework

REGIONAL

AfDBRequests should be submitted to AfDB in English or French However the Bank has the discretion to accept requests made in another official language of a member country

ADBWill conduct translations based on Translation Framework Criteria for undertaking translation audience literacy level relevant languages alternatives time required costs

EBRDRequests in Russian German or French will be responded to in that language May also forward requests to Resident Offices for translation Otherwise response in English

EIBEIBs statutory documents are available in official EU languages while others are available in English French and German Other translation considered if wide interest

IADB Should publish public versions of documents in all languages available

NATIONAL

AFD Information is disseminated in its existing form in the language in which it was drafted

DBSA Must provide a manual with certain information in at least 3 of South Africarsquos languages

OPIC [no mention in regulation]

HOW MUCH DO THE BANKS CHARGE GLOBAL

IFC There may be a standard charge for hard-copy documents or for documents on electronic discs or drives other than a Summary of Investment Information Summary of Advisory Services Project Information or an Environmental and Social Review Summary

MIGAThere may be a standard charge for hard-copy documents or a CD-ROM other than a Summary of Proposed Guarantee or an Environmental and Social Review Summary

WBThe Bank may charge reasonable fees for providing digital or hard copies particularly for requests that are complex or time consuming The bank has not charged fees to date

REGIONALAfDB [no mention in policy]

ADB [no mention in policy]

EBRD [no mention in policy]

EIBAn applicant may be charged a fee to cover for reasonable costs arising from making available requested document(s)

IADBThe Access to Information Committee is responsible for establishing service fees and standards Currently no fees are charged

NATIONALAFD No charge

DBSA A requester must pay an access fee for reproduction search and preparation of the record

OPICFees charged for cost of searching for reviewing duplicating tabulating and compiling information based on intended use of the information Can be waived in public interest

WHAT TYPE OF INFORMATION DO THE

BANKS EXCLUDE FROM DISCLOSURE

The ATI policies list information to be excluded from disclosure either for a limitedperiod of time or forever Exceptions to disclosure are vital to a successful ATI policy inorder to ensure that truly sensitive information which could cause harm if releasedremains closed to the public

Good ATI policies recognize thoughthat these limitations should be clearand limited in order to ensure thatthe policy supports transparencyrather than secrecy

Photo flickrTambako the jaguar

EXCLUDED INFORMATION

Can information be withheld in relation tohellip



Legal or investigative

mattersYes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

Deliberative policy making

processesYes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

Financial information of

the institutionYes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

National security andor

the safety and security of

individuals amp property


Personal privacy Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No

Conservationprotection

of the environmentYes Yes Yes No No Yes No Yes No No No

May Information be

withheld by a member

countrythird party

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No

OVERRIDES

All of the global or regional banks also maintain a right to disclose information that should otherwise be kept confidential in the face of an overriding public interest or other form of harm



Can exemptions ever be

overridden for a public

interest or to otherwise

reduce harm

Yes Yes Yes Yes Yes Yes Yes Yes No YesSome-

times1

Can information be kept

confidential in the public

interestto reduce harm

even if it doesnrsquot fall in an

exception

No No Yes No Yes No Yes Yes Yes No No

1 For example implementation of the exception for personnel or medical files requires OPIC to balance the public interest of releasing the information

APPEALING DECISIONS

TO WITHHOLD INFORMATION



Does the policy or FOI law require the bank to give a reason for denying a request

Yes Yesnot

expli-

citly1

Yes Yes Yes Yes Yes Yes Yes Yes

Is there a provision for internal review4 of refusals


Is there a provision for external review5 of refusals

Yes Yes Yes Yes Yes No Yes Yes Yes No2 No3

May a complaint be brought to an accountability mechanism or national court

Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes

1 In practice the World Bank does explain the reason for denying a request2 Although the person can complain to the Public Protector 3 While OPIC does not have its own external appeals body there is an option to seek mediation services from the Office of Government Information Services at the National Archives and Records Administration In addition an appeal can be taken to the United States federal courts4 Internal appeals are reviewed by employees of the relevant institution5 External appeals are reviewed by people who are convened by the institution but not regular employees

WHO IS IN CHARGE OF

REVIEWING APPEALS

Who is in charge of an internal review Who is in charge of external review

IFC ATI Policy Advisor ATI Policy Panel

MIGA ATI Policy Advisor Access to Information Appeals Panel

WB Access to Information Committee Access to Information Appeals Board

AfDB Information Disclosure Committee Appeals Panel

ADBPublic Disclosure Advancement Committee

Independent Appeals Panel

EBRD Secretary General na

EIB Secretary General EIB Compliance Officer

IADB ATI Committee External Panel

AFD Chief Executive OfficerCommission drsquoaccegraves aux documents administratifs

DBSA Information Officer na

OPIC Vice President amp General Counsel na

STRUCTURES TO

ENSURE

IMPLEMENTATION

Photo flickrDaniel Go

IMPLEMENTATION

Photo flickrlecercle

Implementation of the development bank ATI policies is of course not automatic The development banks have undertaken steps to help ensure that their policies take effect In addition to the creation of divisions within the institutions focused on information access and appeals processes as mentioned above this includes dedicating funds toward implementation training staff monitoring implementation and reaching out to external stakeholders

TRAINING

Photo flickrJonathan

One challenge in implementing the ATI policies isto ensure that everyone in the institutions isaware of the policy requirements and their role inimplementing them Several of the banks haveundertaken institution-wide training to helpensure that everyone understands and is on-board with changes in information managementat the institution They have used differentincentives to encourage participation in thesetrainings The World Bank for example committedto only allow email access to those employeeswho had completed the access to informationtraining

The national banks can sometimes receive training from a national body dedicated to transparency In South Africa for example the Human Rights Commission provides free trainings and seminars for Deputy Information Officers at public and private institutions such as the DBSA

INFORMATION MANAGEMENT

Photo flickrArtform Canada

One of the main challenges associated with implementing an ATI policy is ensuring that information is properly catalogued organized and archived Several of the banks including the World Bank ADB and OPIC have invested in centralized information management systems to make it easier for staff to catalogue and distribute information

The banks have taken different approaches to dividing responsibilities within the institution The ADB for example has designated ldquopublishersrdquo and ldquofocal pointsrdquo throughout the bank to help support implementation if the ATI policy and created an internal help desk to answer staff questions

Some banks have started to provide data in formats that can be read by computer which renders the information useful for a broader range of purposes

MONITORING

Most of the reviewed development bank ATI policies or national freedom of information (FOI) laws include provisions for monitoring implementation and reporting results Some banks (eg the IDB) provide specific monitoring indicators in their policy



Does the policy require

monitoring of

implementation

Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes

How often does the policy

require the institution to

report publically on

implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-

callyrdquoYearly Yearly Yearly

Does

not

specify

Yearly Yearly YearlyYearly amp

quarterly

1 Institutions may report more often than required by their policies For example the World Bank publishes annual reports as well as monthly updates on requests received and granted

OUTREACH

A final but vital step in successful implementation of an ATI policy is ensuring that the public is aware of the policy and how to take advantage of the access to information that it provides Some banks have started to conduct such outreach and training The World Bank for example has held outreach sessions for the members of civil society during its annual meetings In 2013 World Bank staff carried out outreach missions in six country offices in the South Asia and East Asia and Pacific regions

Photo flickrCGIARP CasierflickrInternational Rivers

CONCLUSION ndash

MULTILATERAL DEVELOPMENT BANKS

Transparency can increase accountability strengthen trust enhance legitimacy and help promote the long-term success of investments Many development banks have made progress in recent years to enhance their operational effectiveness through greater transparency This includes in particular the World Bank Group and regional development banks which have created relatively strong policies aimed at improving public access to information The greatest challenge now for these institutions is to ensure effective implementation of their policies to ensure that transparency truly permeates their activities

CONCLUSION ndash


Some national development banks have also created policies to allow access to information about their activities although generally their policies provide less access to information than those of their multilateral and regional counterparts National development bank actions for transparency are often the result of national freedom of information (or access to information) laws requiring transparency at government institutions

Of the national developments banks analyzed in this paper OPIC appears to engage most actively in ensuring public access to information about its activities On the other side of the spectrum lie those national development banks that have yet to create publically available policies ensuring public access to information such as the Brazilian or Chinese development banks

END

Photo flickr Gerardo Pesantez World Bank

INTRODUCTION

Transparency is vital for good governance and effective sustainable development Access to information is a key element of development effectiveness Information allows the public to understand the actions of their government and the financial institutions active in their country and helps people hold these actors accountable for their actions

As a result of public pressure to embrace transparency many development banks have developed policies to allow public access to information about their activities These policies aim to clarify what information is available to the public how the public can access that information and what types of information are to be kept from public access











Information (2012)


Handbook




















Information (2012)


Handbook









Policy













AFD





French Law 2014-773




Decision

DBSA



Information (2012)



OPIC


Act (FOIA)





Statement (2010)

bull FOIA FAQ


NOT REVIEWED





WHY

TRANSPARENCY

Photo flickrFXP







amp LEGITIMACY








WHAT DO THE

POLICIES




















Yes Yes YesSome-





aries












IMPLEMENTATION

GLOBAL

IFC Public Affairs



REGIONAL






NATIONAL






GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END












Information (2012)


Handbook




















Information (2012)


Handbook









Policy













AFD





French Law 2014-773




Decision

DBSA



Information (2012)



OPIC


Act (FOIA)





Statement (2010)

bull FOIA FAQ


NOT REVIEWED





WHY

TRANSPARENCY

Photo flickrFXP







amp LEGITIMACY








WHAT DO THE

POLICIES




















Yes Yes YesSome-





aries












IMPLEMENTATION

GLOBAL

IFC Public Affairs



REGIONAL






NATIONAL






GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END















Information (2012)


Handbook









Policy













AFD





French Law 2014-773




Decision

DBSA



Information (2012)



OPIC


Act (FOIA)





Statement (2010)

bull FOIA FAQ


NOT REVIEWED





WHY

TRANSPARENCY

Photo flickrFXP







amp LEGITIMACY








WHAT DO THE

POLICIES




















Yes Yes YesSome-





aries












IMPLEMENTATION

GLOBAL

IFC Public Affairs



REGIONAL






NATIONAL






GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END










AFD





French Law 2014-773




Decision

DBSA



Information (2012)



OPIC


Act (FOIA)





Statement (2010)

bull FOIA FAQ


NOT REVIEWED





WHY

TRANSPARENCY

Photo flickrFXP







amp LEGITIMACY








WHAT DO THE

POLICIES




















Yes Yes YesSome-





aries












IMPLEMENTATION

GLOBAL

IFC Public Affairs



REGIONAL






NATIONAL






GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END



NOT REVIEWED





WHY

TRANSPARENCY

Photo flickrFXP







amp LEGITIMACY








WHAT DO THE

POLICIES




















Yes Yes YesSome-





aries












IMPLEMENTATION

GLOBAL

IFC Public Affairs



REGIONAL






NATIONAL






GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END


WHY

TRANSPARENCY

Photo flickrFXP







amp LEGITIMACY








WHAT DO THE

POLICIES




















Yes Yes YesSome-





aries












IMPLEMENTATION

GLOBAL

IFC Public Affairs



REGIONAL






NATIONAL






GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END








amp LEGITIMACY








WHAT DO THE

POLICIES




















Yes Yes YesSome-





aries












IMPLEMENTATION

GLOBAL

IFC Public Affairs



REGIONAL






NATIONAL






GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END


WHAT DO THE

POLICIES




















Yes Yes YesSome-





aries












IMPLEMENTATION

GLOBAL

IFC Public Affairs



REGIONAL






NATIONAL






GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END




















Yes Yes YesSome-





aries












IMPLEMENTATION

GLOBAL

IFC Public Affairs



REGIONAL






NATIONAL






GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END






IMPLEMENTATION

GLOBAL

IFC Public Affairs



REGIONAL






NATIONAL






GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END



GLOBAL




REGIONAL






NATIONAL








REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END






REGIONAL






NATIONAL






































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END




































May Information be


countrythird party


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END


OVERRIDES







reduce harm


times1





exception



APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END


APPEALING DECISIONS





Yes Yesnot

expli-

citly1









WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END


WHO IS IN CHARGE OF

REVIEWING APPEALS














STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END


STRUCTURES TO

ENSURE

IMPLEMENTATION


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END


IMPLEMENTATION



TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END


TRAINING









MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END







MONITORING





monitoring of

implementation





implementation1

ldquoongoing

basisrdquo

ldquoongoing

basisrdquo

ldquoperiodi-


Does

not

specify


quarterly


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END


OUTREACH



CONCLUSION ndash



CONCLUSION ndash




END


CONCLUSION ndash



CONCLUSION ndash




END


CONCLUSION ndash




END


END


access to information at development banks

Government & Nonprofit

public access

sustainable development

types of information

global development banksthe

regional development

global development banksinstit

african development

development banksgaia