Memorandum by the Bretton Woods Project
INTRODUCTION
1. The Bretton Woods Project is an independent
NGO established by a network of UK-based NGOs in 1995 to take
forward their work of monitoring and advocating for change at
the World Bank and IMF. See www.brettonwoodsproject.org/about
for more details.
2. This year's hearings on the World Bank
and IMF come at a crucial time for these institutions. Both have
recently taken on new leaders. Both face strong challenges to
their structures and roles. At the same time, the UK has earmarked
its largest-ever increase in support for the World Bank. Clearly,
the scrutiny role of the IDSC has never been more important. For
this reason, we would urge greater cooperation with the Treasury
Select Committee, in these hearings and in the upcoming review
of the structure and performance of the World Bank, the IMF and
the WTO.
3. Broadly speaking, the UK government deserves
praise for both its efforts and the results achieved on debt relief.
While HMG deserves high marks for its positions on aid effectivenessespecially
on reducing detrimental economic policy conditionalitythis
has yet to result in changes in the way the Bretton Woods Institutions
(BWIs) operate. In contrast, we give the government failing grades
for the lack of substantive progress on governance reforms and
for the widening gap between rhetoric on the environment and the
impacts of the policies and projects of the Bank and Fund on the
ground.
INTERNATIONAL FINANCE
CORPORATIONS' SAFEGUARD
POLICY REVIEW:
FROM BAD
TO WORSE
4. The role of environmental and social
safeguards, on issues such as environmental assessment, indigenous
peoples, involuntary resettlement and natural habitats, are of
increasing importance, given increased lending for infrastructure
projects and high-risk extractives (see paragraph 7) and the adoption
of these standards by private banks. The IFC is nearing the end
of its safeguard policy review, which began in August 2004. This
will result in the replacement of the current 10 safeguard policies
of the World Bank Group with eight IFC-specific "performance
standards". A 60-day window has now begun for the public
to make final comments on the drafts, before they go to the Board
in January.
5. The proposed policies will weaken existing
human rights, labour and environmental protections by failing
to make explicit statements on minimum binding standards that
comply with international law. They fail to recognise the IFC's
responsibilities under international law to respect and protect
human rights, including indigenous peoples' internationally guaranteed
rights, and labour rights. They also employ vague and unenforceable
language, particularly in relation to what is required from IFC
and its client. [4]Clear
lines of accountability between the IFC and the client are not
specified. Comprehensive and carefully researched analysis on
each performance standard submitted to the IFC by civil society
was largely ignored. [5]
6. In their current form, the IFC performance
standards are unlikely to avoid future environmental disasters
like those found at the Yanacocha gold mine in Peru or the Chad-Cameroon
and Baku-Ceyhan oil pipelines. Other IFC-funded projects have
highlighted the serious shortcomings of existing safeguard policies
over the past 12 months: An audit by the Bank's internal Compliance
Advisor Ombudsman (CAO) of the Amaggi soybean project in the Brazilian
Amazon found that the IFC had failed to ensure that the Amaggi
group complied with the IFC's environmental and social requirements,
following revelations that Amaggi had been buying soybean from
Amazon farms where slave labour was used[6].
The Marlin goldmine in Guatemala, run by Glamis Gold Ltd has also
been surrounded in tension and violence since its approval in
June 2004. Another CAO report referred to the IFC's lack of oversight
in addressing human rights and the use of security forces, in
light of Guatemala's fragile peace accords and the legacy of its
bloody civil war[7].
In general the CAO has questioned oversight and due diligence
practices and expressed concerns that the proposed system will
exacerbate these problems.
7. UK NGOs were disappointed with DFID's
initial response to the IFC's safeguard policy review. Despite
repeated pressure, DFID failed to act publicly on this issue until
April 2005, shortly before the end of the public comment period.
A two-sided position paper from Hilary Benn was received by the
Bretton Woods Project in July 2005 detailing the comments that
DFID had sent to the IFC. NGOs welcomed the statement that "safeguards
need to be made more consistent both with international conventions
and with the World Bank's safeguard policies", but felt that
DFID could have gone further on this point given its firm commitment
to a rights based approach to development.
Suggested questions
Will DFID remind the IFC that as
a subject of international law it has a duty to respect and promote
universal civil, political, economic, social and cultural rights,
and push for explicit integration of international law in the
final version of its policy and performance standards?
Will DFID demand that IFC improve
accountability, by requiring independent monitoring of large projects
and reporting on the development results at a project level?
Will DFID call upon IFC to reinstate
the requirement that independent third party environmental assessments
are carried out, in particular for high-risk projects?
Will DFID push for action plans to
be developed in a consultative manner with affected communities?
EXTRACTIVES: SLOW
PROGRESS
8. The Extractive Industry Review (EIR),
concluded in December 2003, exposed many problems, and found that
in the vast majority of cases, World Bank financed extractive
industry investments do not alleviate poverty and fail to promote
sustainable development. On average 80% of the energy produced
by such projects is exported to the rich industrialised countries[8].
The Bank's management response rejected the review's recommendations
for a phase-out of support for oil and coal, made symbolic gestures
for increasing support for renewables and watered down language
on the rights of indigenous peoples.
9. UK NGOs in our network cautiously welcomed
the UK government's position[9]
in August 2004 that the Bank should go further to implement a
number of the report's recommendations on support for renewables
and transparency. However they remained concerned that it fundamentally
neglected to hold the Bank to account on a number of significant
points, including "free, prior and informed consent",
the phase-out of fossil fuels and "no-go zones"[10],
and continued to credit the Bank with the ability to raise standards,
set benchmarks and establish best practice.
10. Since then meaningful progress on the
Bank's implementation of its own recommendations has been slow,
particularly on "no-go zones"; "broad community
support"; revenue transparency commitments; poverty impact
assessments and governance risks[11].
NGOs have been in dialogue with the IFC on this issue and attended
meetings in April and September[12].
A report to present the IFC's view of their performance on EIR
implementation is scheduled to go to the board in late December.
The possibility of NGO input is still being considered and Bank
evaluation departments will not be involved. The terms of reference
of the World Bank extractive industries advisory group, which
was meeting in Washington at the time of writing, have yet to
be clarified.
11. The IFC-funded Glamis goldmine in Guatemala
(see paragraph 6) is the first major mining project to be approved
by the Bank following its management response to the EIR in September
2004. It has illustrated numerous problems, and civil society
allege that it has failed to comply with the Bank's commitments,
particularly in relation to environmental assessment, security
forces and human rights and the evaluation of the project's risks
and benefits.
Suggested questions
In light of the slow progress made
over the past 12 months, what steps will DFID take to ensure that
the World Bank fully implements the commitments made in its management
response as quickly as possible?
What contribution is DFID making
to ensure that the implementation report, due out in December
2005, provides a transparent and comprehensive presentation of
the Bank's implementation of its own management response to the
EIR?
CLIMATE CHANGE
12. The G8 Communiqué in July provided
the World Bank with a leadership role in "creating a new
framework for clean energy and development, including investment
and financing". It called on the Bank to put forward specific
proposals at its annual meetings on how it could accelerate the
adoption by developing countries of affordable and lower-carbon
technologies, and asked it to develop an investment framework
to enhance the use of concessional and other funds to mobilise
greater investment in clean energy. In September, the World Bank
and the UK (as G8 presidency) duly launched work on an "Investment
framework for clean energy and sustainable development",
of which early results will be presented next year.
13. However, one year on from the EIR, Bank
support for renewable energy is a mere 6% of its total energy-related
lending and its lead role in the clean development mechanism has
been subject to severe scrutiny[13].
Furthermore, the Bank's response to climate change over the past
five years has been inadequate: country assistance strategies
and relevant sector loans have failed to comprehensively address
climate change and over 80% of the Bank's publicly disclosed lending
in the energy sector did not adequately consider climate change
mitigation issues in its project document[14].
The UK is set to play a key role, and will host a ministerial
conference to launch the "Dialogue initiative on climate
change, clean energy, and sustainable development" on 1 November,
in London.
Suggested questions
One of the greatest barriers to poverty
alleviation will be climate change impacts according to the World
Bank's own reports. In light of that assessment, will HMG challenge
continued World Bank investments in oil extraction projects given
the ultimate green house gas emissions that will occur when that
oil is consumed?
Please could you clarify the outcomes
of the side event at the annual meetings that was hosted by the
UK to discuss follow-up work on G8 climate change initiatives?
As multi-lateral development banks
review their own lending portfolios and prepare proposals on a
new investment framework for the World Bank spring meetings, will
HMG ensure that the Bank not only reviews its clean energy projects
but also other project, sector and country loans that have significant
green house gas emission consequences?
What steps will the HMG take to ensure
that the Bank's framework does not undermine the United Nations
Framework Convention on Climate Change (UNFCCC) and the Kyoto
protocol?
CONDITIONALITY: GOOD
START, HARD
WORK AHEAD
14. NGOs in our UK network have welcomed
the new UK position on conditionality[15]
that calls for an overall streamlining of conditions and an end
to damaging economic policy conditionality. However, there are
concerns that the recently-completed World Bank review of conditionality[16]
missed the point. The Bank insists that the number of conditions
imposed is falling and that the burden of the remaining conditions
is decreasing. [17]Research
from a number of NGOs suggests the opposite. Debt and Development
Coalition Ireland, in a study of 13 recently completed Poverty
Reduction Support Credits[18],
has found that the overall number of conditions is rising and
that obtrusive conditions requiring privatisation persist. [19]
A similar story occurs with conditions requiring
trade liberalisation. While we welcome the language in the UK
objective note for the annual meetings stating that "trade
liberalisation should not be forced on developing countries, whether
through trade negotiations or aid conditionality"[20],
Christian Aid research finds that while the number of trade-related
conditions may have fallen, their burden has not. [21]
Suggested questions:
Given that the Bank's own survey
of government officials revealed that they do not see a difference
between conditions and "benchmarks"[22]
will the UK demand that a criticality test be applied to the use
of benchmarks?
Given that the IMF's Independent
Evaluation Office (IEO) is currently undertaking an evaluation
of the IMF's use of structural conditionality, will HMT push for
the development of parallel good practice guidelines and regular
monitoring of IMF conditions and aggregate conditionality?
DFID's World Bank Institutional Strategy
Paper (ISP) indicators called for "demonstrable progress
on implementation of Poverty and Social Impact Assessment (PSIA[23])
in the Bank (and Fund) produced for 2005 Annual Meetings"does
DFID believe that sufficient progress has been made, and, if not,
what steps will be taken to ensure that PSIAs are carried out
for all relevant policy reforms in a participatory and timely
manner?
AID EFFECTIVENESS:
BANK'S
FAILING GRADE
ON RESULTS
15. We welcome the inclusion in the DFID
WB ISP indicators of a call for "comprehensive reform of
the budget cycle to introduce genuine results-based management"
and "development of a results reporting system at country
level" by end FY06, and reports on corporate performance
to reflect this focus on outcomes by end FY07.
16. However, a number of internal studies
released in 2004-05 pose serious questions about the Bank's abilities
to achieve and monitor results in its work:
From the Operations Evaluation Department's
(OED) Annual Review of Development Effectiveness 2004[24],
come a number of severe criticisms including that the Bank has
conflated increased expenditures in education and health with
reducing poverty but "their actual impact on poverty has
been inadequate", and that social development activities
"are often limited to small parts of projects or are too
rushed or superficial".
The OED's 2004 annual report finds
that monitoring and evaluation (M&E) of results in investment
lending is a "work in progress"; that there are no specific
guidelines on M&E for adjustment lending and that M&E
in the Bank's analytical work "is still rare". Harder
to fix than these deficiencies, says the OED, is fixing an organisational
culture and incentive system "not designed for managing for
results", where Bank staff fear "negative consequences
for slow disbursements, but not for failing to achieve outcomes
or for failing to distil and act on lessons of experience."
[25]
The OED's evaluation of global programmes
finds that the "voices of developing countries are inadequately
represented", that it is "difficult to judge what value
they have added"", and that they "focus largely
on improving the behaviour of developing countries and less on
improving the workings of donor countries, donor agencies or international
organisations".[26]
In light of these OED findings, the G24 has
urged the "reassessment of World Bank country business models
and global programmes that are not yet fully aligned with poverty
reduction goals and progress toward the MDGs."
Suggested questions:
In light of the OED findings, does
DFID consider that the Bank is making sufficient progress on the
results agenda?
As trust funds and global programmes
represent an increasingly large share of Bank activity[27],
what steps does DFID believe should be taken to correct the serious
deficiencies identified by the OED?
INFRASTRUCTURE: FORWARD
TO THE
PAST?
17. The World Bank has announced a rapid
scaling-up in its infrastructure lending, with plans for it to
reach 40% of the entire portfolio within a few years. While the
Bank vice-president for infrastructure has assured civil society
that the institution has "learned the lessons of the past"[28],
there are serious concerns that it has not.
Hearings in the US congress have
revealed the extent to which corruption has pervaded large infrastructure
lending. [29]
A June 2004 report by World Bank
staff found that the Bank's approach to the privatisation of infrastructure
continued to be in part ideologically-driven rather than evidence-based,
saying privatisation had been "oversold and misunderstood".[30]
The most recent progress report on
infrastructure[31]
failed to stress the poverty reduction impact of infrastructure
lending. In its objective note for the annual meetings, HMG stated
that there is a need to "stress the importance of clear poverty
reduction objectives in infrastructure planning".
Numerous projects approved within
the last year have been opposed by civil society for exhibiting
unacceptable levels of social and environmental risk and for failing
to adequately consult project-affected peoples: National Drainage
Programme, Pakistan[32];
Nam Theun 2 dam, Lao PDR[33];
Allain Duhangan hydropower project, India[34].
Several projects pending approval, such as the Kala Bagh dam in
Pakistan and the Bujagali dam in Uganda face similar complaints[35].
Suggested questions:
How will DFID encourage the World
Bank to adopt a poverty-centred approach to infrastructure, to
avoid the pitfalls of its past lending in this area?
Following the commitment of the EIB
and the EBRD to align its lending to the recommendations of the
World Commission on Dams, will the UK urge the World Bank to do
so?
GOVERNANCE: FRESH
PERSPECTIVE DESPERATELY
NEEDED
18. In its last submission to the IDSC,
the Project documented the failure to make progress on the issue
of democratisation of the BWIs over five consecutive spring/annual
meetings. That number has now reached seven consecutive spring/annual
meetings. We agree with the UN Secretary-General[36]
and, more recently, with the IMF's medium-term strategic review[37]
that the failure to address the issues of fair quotas and voice
for developing countries is "straining the legitimacy of
the institution". It is clear that the "governance roadmap"
process led by Trevor Manuel which was intended to break the logjam
on this issue has failed. The torch is now being passed to the
thirteenth review of IMF quotas, a process which is to be completed
by January 2008. However, beyond the inability of this review
to address the specific needs of World Bank reform, without an
independent process to overcome the conflict of interests at the
Board, the quota review is unlikely to come up with a satisfactory
resolution.
19. On the question of leadership selection,
UK civil society were disappointed that HMG first supported the
carve-up which saw yet another European head the IMF, and then
give high-level backing to the US administration's unilateral
anointment of an inappropriate candidate for presidency of the
World Bank. While we support DFID's call in its WB ISP for "demonstrable
improvements in recruiting senior Bank staff in an open, meritocratic
and transparent manner", we can see no way in which these
words are consistent with HMG's actions. Most recently, two more
Europeans have been appointed to top posts at the IFC, and finance.
20. We welcome increased attention given
to the issue of parliamentary scrutiny of IFI financing agreements
and national development strategies by both DFID[38]
and by the World Bankx[39]
and IMF. However, civil society organisations in the networks
we work with continue to be alarmed at BWI transgressions of parliamentary
sovereignty[40].
Most recently, two parliamentarians who travelled to Washington
representing over 1000 MPs worldwide who have signed the International
Parliamentarians' Petition[41],
were blocked from attending a G24 meeting by IMF staff. [42]
21. We note a number of improvements in
HMG accountability to parliament and UK civil society in its dealings
with the IFIs: in particular, we welcome DFID's new WB ISP which,
for the first time, includes objectives and indicators, and we
look forward to the first meeting to review progress on such and
would hope for IDSC participation; UK NGOs appreciated receiving
UK objectives notes for the annual meetings 10 working days in
advance of the annual meetings, and we would encourage a greater
role for the IDSC in scrutinising such; and we look forward to
the publication of the National Audit Office evaluation of UK
contributions to multilateral agencies.
22. However, we note a number of areas where
improvement is still needed: we urge HMT to follow DFID's lead
in the publication of specific objectives and indicators for its
dealings with the IMF; the annual reports of both DFID (and the
World Bank) and HMT (and IMF) failed to respond to salient issues
raised by the institutions' own evaluation and complaint bodies
or explain whether UK objectives for spring/annual meetings are
achieved; finally, we were disappointed by the failure of the
NAO to consult civil society on its study of UK contributions
to the multilaterals and have been told that this study will not
include a "value for money" examination.
23. On the issue of transparency, we welcome
advances made in the Bank's recent disclosure policy review which
include publication of board minutes and a pilot programme to
disclose operational policy reviews simultaneously with their
distribution to the board. However, there was disappointment over
the failure to publish board transcripts, country strategies and
programme documents for PRSCs.
Suggested questions:
How will HMG support the creation
of an independent, credible process to advance discussions on
democratising the World Bank and IMF? With an HMT official slated
to become the next chair of the IMF sub-committee at the European
Parliament, will the UK spearhead a discussion of the rationalisation
of European representation on the board of the IMF?
Will HMG, as part of the IMF quota
review, demand a re-tabling of the question of leadership selection,
and make explicit its refusal to support a system whereby Europe
and the United States continue to share the spoils of leadership?
Will HMG encourage the Bank and Fund
to develop good practice guidelines in their dealings with elected
representatives?
What can HMT and DFID do to improve
take-up of the recommendations of the Bank and Fund's evaluation
and complaint bodies?
Will HMT commit to produce medium-term
objectives and indicators for its dealings with the IMF?
Will HMG support a move to the presumption
of disclosure at the IFIs?
IMF MACROECONOMIC
AUSTERITY
24. We welcomed HMT calls in its annual
report on the IMF for increased macroeconomic flexibility. This
is in keeping with an appeal made in the G24 communiqué
at the annual meetings for the IMF to support countercyclical
policies. At last year's IDSC hearings, HMT representative Stephen
Pickford said he "believed there was evidence of increased
flexibility on the part of the Fund". Recent studies by ActionAid
International argue the opposite. Fund austerity on inflation
rates, fiscal deficits and social spending are blocking dynamic
growth and achievement of the Millennium Development Goals. There
are fresh concerns that the introduction of a new policy instrument,
the Policy Support Instrument, will extend the pre-dominance of
the Fund's static view of allocative efficiency to non-borrowing
countries.
25. In both its review of the IMF and capital
account liberalisation[43]
and the Fund's handling of the Argentine crisis[44],
the Independent Evaluation Office (IEO) found that the Fund should
provide more input into rich countries' financial supervision
to reduce `herd behaviour'. Despite this admonishment, the Fund's
medium-term strategic review once again places the onus of responsibility
on the most vulnerable countries to adapt to the vagaries of global
capital, saying that "capital account liberalisation is a
reality, a part of globalisation" and "what the Fund
must be in a position to do is to advise on how best to manage
the process".
Suggested questions:
What steps will HMT take to ensure
that calls for increased macroeconomic flexibility at the Fund
are followed-up on?
Will HMT encourage the Fund to take
a stronger role in regulating the herd behaviour of investors
in rich countries? Will it ensure that capital account liberalisation
is never included as part of Fund conditionality?
October 2005
http://www.neweconomics.org/gen/zsysPublicationDetail.aspx?pid=196
4 http://www.brettonwoodsproject.org/article.shtml?cmd[126]=x-126-235769 Back
5
http://www.grrr-now.org/. For further information contact Bretton
Woods Project. Back
6
http://www.brettonwoodsproject.org/article.shtml?cmd[126]=x-126-235769 Back
7
http://www.cao-ombudsman.org/pdfs/CAO-Marlin-assessment-English-7Sep05.pdf Back
8
Up in smoke? Threats from, and response to, the impact of global
warming on human development, the working group on climate
change and development, 2004. Available at: Back
9
http://www.dfid.gov.uk/news/files/update-extractiveindustriesreview-full.asp Back
10
http://www.brettonwoodsproject.org/article.shtml?cmd[126]=x-126-72213 Back
11
http://www.brettonwoodsproject.org/article.shtml?cmd[126]=x-126-235789 Back
12
http://www.brettonwoodsproject.org/AMEIR05 Back
13
http://www.brettonwoodsproject.org/article.shtml?cmd[126]=x-126-351465 Back
14
http://pubs.wri.org/pubs-description.cfm?PubID=4082 Back
15
http://www.dfid.gov.uk/pubs/files/conditionality.pdf Back
16
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-351555 Back
17
http://www.worldbank.org/conditionality Back
18
The PRSC is the World Bank's primary structural adjustment loan
for low-income countries, meant to support a country's Poverty
Reduction Strategy (PRS). Back
19
http://www.debtireland.org/resources/ddci-re-PRSCReportFINAL.htm Back
20
http://www.dfid.gov.uk/news/files/imf-wg-meetings05.asp Back
21
http://www.christian-aid.org.uk/indepth/509condition/index.htm Back
22
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-351555 Back
23
Poverty and Social Impact Assessments are ex-ante assessments
of the likely impact of proposed reform alternatives. Back
24
http://www.worldbank.org/oed/arde/2004 Back
25
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-178181 Back
26
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-108348 Back
27
For more on the role of trust funds at the World Bank, see http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-356108 Back
28
http://brettonwoodsproject.org/infrastructuream05 Back
29
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-51232 Back
30
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-62683 Back
31
http://siteresources.worldbank.org/DEVCOMMINT/Documentation/20651863/DC2005-0015(E)-Infrastructure.pdf Back
32
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-178207 Back
33
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-174503 Back
34
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-83023 Back
35
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-351566 Back
36
http://www.brettonwoodsproject.org/article.shtml?cmd[126]=x-126-235788 Back
37
http://www.imf.org/external/np/omd/2005/eng/091505.pdf Back
38
http://www.dfid.gov.uk/pubs/files/conditionality.pdf, pg 2. Back
39
http://siteresources.worldbank.org/DEVCOMMINT/Documentation/20651869/DC2005-0017(E)-PRSReview.pdf,
pg. 4. Back
40
http://www.ippinfo.org/documents/Keptinthedark.pdf Back
41
http://www.ippinfo.org Back
42
http://brettonwoodsproject.org/g24am05 Back
43
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-235765 Back
44
http://brettonwoodsproject.org/article.shtml?cmd[126]=x-126-65659 Back
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