SAVANAS E ENSEADAS – LDADevelopment Strategy and Business Solutions

Lisbon, Portugal

Overview of Results of the 3rd

IRM Review

SAVANAS E ENSEADAS – LDA 2

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4

7

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3

10

13

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Objectives and Scope of Review as per TOR

Important Relationships

IRM and Knowledge Management

Effectiveness/Efficiency of BCRM as an administrative unit

Functions

Conclusions and Identified Gaps

Recommendations

Staffing and Budget

Comparison with other IAMs12

SAVANAS E ENSEADAS – LDA 3

• Assessment of the extent to which IRM has been an effective recourse mechanism for people affected by a Bank financed operation and a useful accountability instrument for the Bank.

• Revise the present IRM Enabling Resolution and its Operating Rules and Procedures (IORP)

SAVANAS E ENSEADAS – LDA 4

IRM & Boards of Directors

Needs to be better reflected in an amended TOR for CODE

Principles of the oversight role of the Boards/Committee of Operations and Effectiveness (CODE) viz-a-viz the BCRM is clear.

Need for more hands-on relationship with Boards, greater effort by IRM to constantly update the Boards even in absence of active cases, ensure a feedback loop between the Boards and IRM.

Need for a clear distinction between the role of CODE as against that of the Boards at large

SAVANAS E ENSEADAS – LDA 5

IRM &

Management

Problematic relationship

Timelines regarding

reports not respected

Disclosure of IRM existence in

project and policy

documents, and to clients

Neglect in facilitating access to

requisite staff and project

documentation

Management’s lack

incorporation of lessons learned

by IRM work, whether in new

policies, procedures, or

guidance to staff

SAVANAS E ENSEADAS – LDA 6

BCRM &

CSOs / Complainants

Lack of responsiveness and adherence to deadlines,

weak communication

s

Lack of anti-retaliation measures

Lack of support for

complainants to send in complaints although

required by OIRP

Strategic communication

and outreach necessary

Related to IORP where certain

provisions were making access to IRM difficult

Perception of IRM tended to

be largely negative

SAVANAS E ENSEADAS – LDA 7

➢Very few Advisory Notes produced, most in 2019

➢Were not developed according to approved Guidelines;

➢Did not go through the prescribed review process, no

feedback was received on them

➢Not disseminated or posted on website.

➢Did not follow the Guidelines in terms of selection criteria,

processing or expected results;

➢No monitoring of whether Management implemented

recommended actions;

➢Possible conflict of interest in case of complaints received

on same project;

➢Question whether Spot-Checks are the best use of scarce

BCRM resources especially in view of its limited staffing.

Advisory Notes Spot-Checks

SAVANAS E ENSEADAS – LDA 8

BCRM Structure:

IRM is independent from

and does not report to

Management.

SAVANAS E ENSEADAS – LDA 9

Staff profiles and grades

BCRM BudgetStaff mandates and roles

Number of staff

SAVANAS E ENSEADAS – LDA 10

• indicator is existence of specific well-defined steps in the complaints process

• IORP includes the number and sequence of steps in complaints handling

Predictability of functions:

• indicator is extent to which there is easy access to information on where in the process a complaint is,

• access to draft reports, notifications of decisions, etc.

Transparency of functions:

BCRM does well on predictability but not

on transparency

SAVANAS E ENSEADAS – LDA 11

Problem Solving

• Gaps in PS function: not following the set procedure;

• Important steps missed, lack of clear methodology;

• Timelines not realistic;

• Lack of Lesson learning from vast PS experience;

• Lack of staff with solid PS expertise and experience

Compliance Review

• Lack of adherence to deadlines on part of both BCRM and Management;

• Ambiguity in Rules about the timing of different steps;

• Role of the Director in process;

• Monitoring length and nature.

SAVANAS E ENSEADAS – LDA12

Relationship with the Board of

Directors:

Knowledge creation and management

:

Relationship with

Management:

IAMs structure,

budget and

Functions:

• Structure compares with ADB, IADB and IPN of World Bank.

• In terms of number of staff IRM compare favourably the problem is that positions are not filled, budget in middle of range.

• Three functions Compliance Review, Problem Solving and Advisory , BCRM has all.

• PS function currently missing important steps such as assessment.

• CR follows best practice but not abiding by timelines.

• Fundamental function of most IAMs.

• None of the IAMs have a Spot Check.

• The litmus test for success: The extent to which the institution reacts to and makes changes in response to these knowledge products, whether through policy changes and/or new policies.

• Importance of a dedicated communication staff to implement the communications and/or outreach strategy with an appropriate budget, updated webpage and greater use of social media;• Importance of having a transparent relationshipwith complainants and facilitating access to the mechanism , while keepingcomplainants updated.• Importance of having anti-retaliation measures;• Consider an external advisory group

• Rather problematic in all IAMs

• Clear obligation of the IAM and Management to cooperate fully on availability of information on a complaint, and or adherence to deadlines for submission/presentation of Management documentation.

• Good practice is to appoint a focal point in Management to lliaise between the IAM and Management

• Most IAMs report to a Board Committee: Special oversight function making this relationship crucial for the effectiveness of IAMs.

• Good examples of this relationship from IPN of the WB, where there is constant communication both formal and informal between IPN and Board/CODE

Relationship with

Complainants/ CSOs :

SAVANAS E ENSEADAS – LDA 13

RT acknowledges IRM success in solving various problems raised in Complaints

RT acknowledges IRM success in identifying areas where Management has not acted in compliance with its own policies resulting in harm to communities

However, gaps remain

IRM/BCRM occupy a rather marginalized position within the institution, preventing trust and credibility required for its’ work and recommendations to be taken seriously by both Management and complainants/civil society

Lack of resources, especially human resources, hindering efficiency and leading to long processing and lack of transparency of its operations

Inability of IRM to act as a source of valued knowledge and lessons learnt for the institution

SAVANAS E ENSEADAS – LDA 14

Recommendation I: Changing the Image and Stature of IRM/BCRM

Clear and strong messages from the President, Senior

Management and the Boards about:

BCRM as a fundamental player in the Bank’s accountability system

Accountability as a Bank-wide concern and effort

1

2

Clearly embedding this

message in various Bank publications, speeches and

landmark events.

Specific Actions

TORs of CODE amended to

clearly define its role viz-a-viz IRM/BCRM,

differentiate the roles of CODE

and the Board, establish strong feedback loop

even in the absence of active

cases.

SAVANAS E ENSEADAS – LDA 15

Recommendation II: Efficient Preventive Measures

Management needs to be more proactive in

identifying early stage solutions to harms resulting from non-

compliance with Bank policies and safeguards

3

1 Management should ensure that all projects under implementation,

with a greater focus on Category I projects have

functioning GRMs.

Specific Actions

Management needs to be much more proactive in anticipating problems related to compensation and involuntary resettlement before they occur.

2

Country and Regional offices must be well equipped to handle minor complaints before they escalate.

SAVANAS E ENSEADAS – LDA 16

Recommendation III: Improving BCRM Communication and Outreach

Sharing the right information directed at

the right target audience plays an important role in

establishing a relationship of trust and

transparency with BCRM for all stakeholders concerned.

3

1 BCRM to develop a functioning

communication and outreach strategy that is in close alignment with that of the Bank

Specific Actions

Strategy structured to create visibility

for the BCRM, simplify the IRM processes for the stakeholders, and

enable information sharing and knowledge

management at a continental level as

well as internally within the Bank

2

Focused on:

i) internal communication ii)

external communication and

outreach iii) the Bank’s website and iv)

social media

SAVANAS E ENSEADAS – LDA 17

Recommendation IV: Knowledge Management and Advisory Services

- BCRM has not used the vast amount of

experience and lessons learnt to

influence the Bank’s policy agenda. Efforts of BCRM focused on

conducting Spot-Checks, around which many drawbacks have

been identified;

- Institution must change to

accommodate results of knowledge work.

3

1 Spot Checks to be undertaken in only

very specific circumstances

Specific Actions

Roster of Experts should be closely

involved in the production of these Notes

2Emphasis should be placed on Advisory Notes, which must

contribute to lessons learning

about non-compliance and specific policy

challenges faced by the Bank

4Ensure wide dissemination of

these Notes through publications and the

IRM webpage.

SAVANAS E ENSEADAS – LDA 18

Recommendation V: Financial and Human Resources

- BCRM staffing situation raised

repeatedly by most stakeholders;

- Terms and Recruitment of

Director and Roster Experts;

- Roles and Responsibilities of

Director and Roster Experts.

3

1 Accelerated recruitment drive, staff profiles and

some stop gap measures

Specific Actions

Allow recruitment of former Bank staff as Roster Experts after cooling off period, expand responsibilities.

2Mandate of Director to be reduced, responsibilities

streamlined

SAVANAS E ENSEADAS – LDA 19

Recommendation VI: Towards a Strategic Relationship with Management

- Improved, more strategic relationship and communication between IRM and Management will

improve the complaints handling

process;

- Will ensure remedy for complainants;

- Will ensure lesson learning and

appropriate policy.

3

1 Focus on appropriate due

diligence upstream in order to ensure

that facts are correctly presented

by both IRM and Management

Specific Actions

All PARs, ESIAs and Bank policy documents to fully disclose the existence and role of IRM

2Focal point designated within

Management, to act as a liaison between

Management and IRM/BCRM

4Clear messages to Country and

Regional Offices regarding the

important role they play in the IRM

process

SAVANAS E ENSEADAS – LDA 20

Recommendation VII: Streamlining Documentation

Length, structure, content and tone of

both IRM and Management

documents need to be streamlined.

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2

Agreement on a standard format of Management

Responses, Management

Action Plans, and IRM Eligibility

Reports, Compliance Review and

Problem-Solving Reports

Specific Actions

Regarding tone, both

Management and IRM to avoid

accusatory tones and opt for

finding solutions rather than

questioning each other’s

arguments

SAVANAS E ENSEADAS – LDA 21

Recommendation VIII: Revision of IRM Operating Rules and Procedures (2015)

IRM rules were approved in 2015

they no longer respond to

International best practises and

changes within the Bank and IRMC.

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1

Specific Actions

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4

5

6

Simplifying the rules and

weeding out any ambiguities

Ensuring that the IORP facilitate access to IRM

Clarifying roles and

responsibilities of the different

stakeholders to IRM process

Adding aspects that were not

taken into consideration in

the current version; notably

as regards reprisals and protection of Complainants

Taking into account

comments made by various

stakeholders including BCRM

staff, members of CSOs and

complainants

Benchmarking and International

Best Practice