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IMF Transparency Policy Review: CSO Views
The IMF has reviewed its Transparency Policy. Civil society submitted some comments and suggestions (see below).
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I. Civil Society Organization (CSO) Views on the IMF’s Transparency Policy
To ensure that a wide range of views are reflected in the 2013 Board paper, Civil Society Organizations (CSOs) were invited to express their views on the Fund’s transparency policy. The consultation comprised two approaches. First, CSOs were invited to respond to an online consultation page. Second, representatives from selected CSOs participated in a conference call to exchange views on the Fund’s Transparency Policy.[1][2]While CSOs conceded that some improvements have occurred since the 2009 review, they saw the need for further reforms to catch up with current international standards. The discussions centered around five key themes summarized below:
Overarching Principles: Follow the lead of other IFIs
- Despite recent reforms, the Fund’s transparency policy continues to be seen as more restrictive than that of other IFIs, including the World Bank. The CSOs urged the Fund to follow the lead of other IFIs in the following areas:
- Presumption of disclosure. The World Bank moved in 2010 to a policy of full disclosure except for a limited set of documents on a “negative list”, an approach that was seen as superior to the Fund’s practice of seeking consent from country authorities or Board approval prior to publication.
- Board meetings. Some institutions provide live streaming of Board meetings and the World Bank issues summary minutes immediately after the meeting. In contrast, the Fund’s summing ups are issued later, without attribution, and verbatim minutes are made available to the public with a five-year lag. More generally, information about the Fund Board’s calendar and activities was seen as limited and often unreliable.
- Governance of information releases A number of IFIs have clear procedures for handling information requests from the public and have established independent bodies to adjudicate complaints in this area, including appeals when information requests are turned down. The IMF has not established such developed procedures.
Consultations with stakeholders: Gather broader perspectives
- The Fund should strike a balance between its duty to advise country authorities and its wider responsibility to countries as a whole. In response to worldwide moves towards participatory democracy, the Fund should step up its interaction with other stakeholders, e.g. parliaments, opposition groups, CSOs and trade unions.
- The Fund’s handling of consultations with CSOs on policy papers is seen as suboptimal, including the current review of the transparency policy, as CSOs were allowed only to provide general comments ahead of time, limiting their scope to influence decisions. Instead, CSOs should be given an opportunity to review and comment on draft policy papers before issuance to the Executive Board.
- The Fund should increase its interactions with CSOs and representation on public forums, including through IMF’s resident representatives (res. rep.) offices.
- The Fund should publish CSOs’ full comments on its website.
Candor and timely disclosure: Increase transparency on decision-making processes
- Greater candor and timely disclosure of information would enhance the Fund’s accountability, and reduce the risk of it being used as a scapegoat by governments.
- The emphasis on market sensitivity in the Fund’s transparency policy was seen as overblown. The Fund should define more clearly the concept of “market sensitivity”. The Fund should put the emphasis on keeping the public informed rather than on maintaining market stability in cases when these two objectives come into conflict. In general, the Fund should realize the difference between secrecy and responsibility.
- Fund documents should clearly highlight differences of views between the various parties concerned: the Board, staff, management and the authorities. This would strengthen staff independence and avoid the suppression of views, as flagged by the IEO. More attribution of views was also seen as needed in Board summing ups.
- The Fund should disclose the list of unpublished and modified documents, as well as modification requests with justifications as to why they have been permitted. If documents are modified, they should be published with black line redactions to clarify the nature of the change.
- While the Fund was seen as having made progress at releasing information on “outcomes”, but information on “processes” that lead up to decisions is more limited. There is a need for more systematic disclosure on how decisions are made, including on technical assistance funding and program conditionality.
Evenhandedness: a new approach to information sharing
- The Fund should be more willing to respond to information requests from outside stakeholders. This would improve evenhandedness as information would be “pushed out” in addition to voluntary publication.
- The Fund should systematically include a section on stakeholders’ views in staff reports.
Communication: Cut back on jargon and improve ease of access
- The Fund should cut back on jargon and in general use language that makes documents more accessible to the general public. More documents—including policy papers—should be translated, including into languages beyond the five official UN languages. Country papers should be translated into at least the language of the country concerned.
- The Fund should make a clearer distinction between papers with policy content cleared by the Fund, and those that do not represent the Fund’s official position. Doing so would help clarify the Fund’s position on key issues and the Fund’s message to stakeholders.
- The Fund should create a web page for all resident representative offices, and those offices should maintain a mailing list of key CSOs and distribute news releases to them electronically.
- Information related to a country should be housed in a single location to facilitate searching. In addition, country pages on the IMF website should include a factsheet on IMF involvement with the country, and a list of forthcoming and recently completed interactions with authorities (staff visits, technical assistance, meetings with CSOs, etc.). Information on ways to engage with the visiting teams should also be disclosed.
[1] CSOs were also invited to provide comments via the online CSO Consultation Page for 2013 Transparency Review). Two institutions provided written comments: Global Research Priorities in Global Governance (UK) and New Rules for Global Finance (US).
[2] Eight organizations participated in the conference call, which was held on March 8th: Save the Children (Norway), European Network on Debt and Development (Belgium), Human Rights Watch (US), ITUC (US), Oxfam (US), ONE Campaign (US), Center for Law and Democracy (Canada), The Bretton Woods Project (UK).