OFFICE OF ETHICS & BUSINESS CONDUCT 2010...

2010 ReportO F F I C E O F E T H I C S & B U S I N E S S C O N D U C T

A commitment to Core Values and high ethical standards is important to the success of the World Bank Group (WBG). The Offi ce of Ethics and Business Conduct (EBC) promotes the development and application of high ethical standards by staff members in the performance of their WBG duties. EBC is an independent offi ce that reports directly to the World Bank Group President.

EBC has four strategic business lines:

■ OUTREACH AND COMMUNICATION Providing communication, outreach, and training

on business conduct

■ TRUST AND TRANSPARENCY Managing programs to promote trust and transparency,

including handling confl icts of interest and fi nancial disclosure

■ RESPOND AND RESOLVE Responding to and investigating certain types of allegations

of staff misconduct

■ KNOWLEDGE MANAGEMENT

Tracking trends and providing insights to senior management

Cover photo:Hemera Techologies / AbleStock.com / Photos.com

Ethics & Business Conduct

Contents

LETTER FROM THE CHIEF ETHICS OFFICER 3

EVOLUTION OF EBC 4

OUTREACH AND COMMUNICATION 6

TRUST AND TRANSPARENCY 10

RESPOND AND RESOLVE 15

KNOWLEDGE MANAGEMENT 22

EBC SCORECARD 24

RAISING A CONCERN 25

2 ethics & business conduct

32010 report

Letter from the Chief Ethics Offi cer

In recent years, the role of the World Bank Group has changed

signifi cantly. The institution has renewed and deepened its

focus on delivering results to clients, simultaneously moving

toward greater openness and accountability. The Bank Group’s

internal justice environment has mirrored this shift by aiming to

meet institutional needs and better serve staff who face

increasing pressures in this climate.

In July 2009, EBC’s mandate expanded to include investigating

allegations of many forms of staff misconduct. This report

is both a one-year progress report on the Offi ce’s new

“Respond and Resolve” investigative function and an update

on many other substantive developments made from the time

of the last report.

Highlights of EBC’s accomplishments include the release

of a new global World Bank Group Code of Conduct, the

development of a curriculum of both standard and customized

ethics training, and the implementation of a multitiered

fi nancial disclosure program. On the knowledge management

front, EBC administered the fi rst Bank Group-wide Ethics Survey.

It is being used to benchmark progress in addressing business

conduct concerns and better manage such risks. These activities

are detailed in the pages that follow.

Our accomplishments refl ect the meaningful contributions of

stakeholders throughout the Bank Group and the unwavering

dedication of EBC staff. To all of these individuals, I convey my

deep appreciation.

Anne Marie TaylorChief Ethics Offi cer


volution of EBCEAs the IJS has changed, EBC’s role also has transformed. In some respects, however, the Offi ce has come full circle from its establishment in 1991 as the Offi ce of Professional Ethics (fi gure 1).

From its inception, the Ethics Offi ce has managed the Bank Group’s educational outreach on business ethics and has provided guidance to staff on a range of business conduct matters. The Offi ce later partnered with other units to develop the fi rst Living Our Values (LOV) courses. LOV has been adopted as the name of the Bank Group’s Code of Conduct and, since the release of the updated Code in 2009, the term Living Our Values also refers to the Bank Group’s Code of Conduct training curriculum.

When fi rst established, the Offi ce handled all allegations of misconduct, including investigations. This mandate changed in 2001 with the creation of the Institutional Integrity unit. From that point until July 2009, when Staff Rule 3.00 took effect, EBC continued to provide advice on business conduct matters but did not have the mandate to investigate. The recommendations of the 2007 Independent Panel Review of the World Bank Group Department of Institutional Integrity, headed by Paul Volcker (“Volcker Report”), led to the creation of the new Staff Rule 3.00. This rule transferred the responsibility to investigate staff misconduct (excluding signifi cant fraud and corruption) to EBC and formalized EBC’s four strategic “pillars,” or functions, which form the structure of this report.

THE WBG’S INTERNAL JUSTICE SYSTEM (IJS), OF WHICH EBC IS A PART, HAS UNDERGONE SIGNIFICANT REFORMS TO CREATE A MORE TRANSPARENT PROCESS FOR STAFF.

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As the WBG further decentralizes, it is especially important for staff to have a universal understanding of business conduct expectations and how to appropriately handle situations that can arise with both internal and external stakeholders.

EBC’s presentations and training content are reviewed regularly to address emerging business conduct issues. Prior to FY09, outreach was conducted primarily through New Staff Orientation sessions and ethics workshops for interested staff groups. With the launch of the updated Code of Conduct in FY09, EBC developed a comprehensive new training curriculum entitled Living Our Values (LOV) and an accompanying mandatory e-learning course for all staff.

EBC OUTREACH TO STAFF To communicate directly to staff the business conduct expectations of the institution and the resources available to assist staff, EBC undertakes a range of outreach activities. These include formal briefi ngs and presen-tations for staff and managers in Washington and Country Offi ces. EBC trainers on mission frequently meet with staff in both groups and individu-ally. Hundreds of staff are reached through these efforts every year. Additionally, EBC hosts informal gatherings to facilitate conversations among stakeholders on business conduct matters.

utreach and Communication PROVIDING COMMUNICATION, OUTREACH, AND TRAINING ON BUSINESS CONDUCT

EBC’S OUTREACH AND COMMUNICATION EFFORTS ARE DESIGNED TO RAISE AWARENESS OF HOW THE WORLD BANK GROUP’S CORE VALUES APPLY IN THE WORKPLACE.

As the WBG further decentralizes, it is especially important for stahave a universal understanding of business conduct expectations how to appropriately handle situations that can arise with both intand external stakeholders.

PROVIDING COMMUNICATION, OUTREACH, AND TRAINING ON BUSINESS CONDUC

EBC’S OUTREACH AND COMMUNICATION EFFORTS ARE DESIGRAISE AWARENESS OF HOW THE WORLD BANK GROUPCORE VALUES APPLY IN THE WORKPLACE.

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72010 report

EBC seeks to build partnerships to leverage limited resources, and the offi ce collaborates with Internal Justice System (IJS) partners on various events. These have included participating in IJS Day and Diversity and Inclusion Day, and hosting guest speakers of interest to staff. EBC’s partnership with Human Resources professionals enables the latter to assist in business conduct-related Country Offi ce outreach.

TRAINING CURRICULUM Each year, EBC receives numerous requests to provide ethics training to groups of staff. To ensure that the training is both of high quality and highly relevant to issues faced by work units, a new Living Our Values (LOV) curriculum1 was launched upon release of the updated Code of Conduct in November 2009. The curriculum includes a mandatory e-learning module (see page 8) as well as face-to-face training. The latter consists of a half-day workshop for staff teams and full-day workshops for managers (piloted; full deployment planned for FY11) and HR profes-sionals (available on request). EBC works with clients in advance to ensure that the course content and case studies are timely and tailored to the respective groups. In addition to the LOV curriculum, EBC has Living Our Values presentation at Burundi Country Offi ce Retreat, FY09

Photo: Annie Kihara

TABLE 1. NUMBER OF STAFF RECEIVING EBC FACE-TO-FACE TRAINING BY TYPE

FY07 FY08 FY09 FY10

Orientation 954 925 1,557 1,434

LOV Training (half-day) 0 34 347 940

Treasury Training 0 346 0 312

Controls, Ethics and You 150 52 72 85

Country Director/Manager Training 0 40 26 64

Train-the-Trainer Sessions 8 9 14 21

Specialized Ethics Training 0 0 20 16

Ethics Workshop (full day) 878 415 0 0

HRO Training (full day) 35 50 35 0

LOV Manager Training Pilot 0 7 10 0

Manager Training 42 19 0 0

Total 2,067 1,897 2,081 2,872

1. The LOV training is distinct from an earlier Living Our Values workshop developed by the Confl ict Resolution Service units in 2003, which sometimes was used to address specifi c workplace concerns.


FIGURE 2. NUMBERS OF STAFF REACHED THROUGH EBC COUNTRY OFFICE OUTREACH AND TRAINING

*Note: Includes Ethics Officer Outreach

● Croatia 94

● France* 46

● Moldova 24

● Romania 30

● Turkey 27

● Turkey 43

● Ukraine 67

EUROPE/CENTRAL ASIA

● Pakistan 72

● Afghanistan 36

● Bangladesh 120

● India 98

● India 36

● India* 99

● Nepal 35

● Sri Lanka 34

SOUTH ASIA

● Cambodia 48

● China 41

● China 82

● Indonesia 107

● Vietnam* 57

● Vietnam 73

EAST ASIA/PACIFIC

● Benin 13

● Congo 15

● Côte d’Ivoire 27

● D.R. of Congo 70

● Ethiopia 65

● Ghana 39

● Kenya* 63

● Lesotho 6

● Madagascar 49

● Nigeria 86

● Senegal 45

● South Africa 57

● South Africa 84

● Tanzania 30

AFRICALATIN AMERICA/CARIBBEAN

● Colombia 28

● Mexico 37

FY06 (Total = 476) FY07 (Total = 339) FY08 (Total = 325) FY09 (Total = 37) FY10 (Total = 806)

collaborated with partners to design training for specifi c groups, including all Treasury and GSD staff.

To increase EBC’s capacity to deliver LOV training globally, two train-the-trainer (TTT) sessions were conducted in FY10 to equip WBG staff to deliver the LOV training — with further TTT sessions scheduled in FY11. EBC facilitators on mission collaborate regularly with trained Country Offi ce-based HR profes-sionals to enable them to effectively facilitate ethics workshops. EBC aims to have trained facilitators based in all regions by FY12.

E-LEARNING MODULETo provide a foundation of business conduct knowledge for all staff,

EBC developed a mandatory e-learning course, entitled Living Our Values: Introductory Course. This interactive e-learning uses scenarios to address common workplace concerns and introduces staff to the various IJS resources which they can access to help resolve workplace issues. The module supplements EBC’s existing e-learning programs on the Gift Policy and Political Activities.

OUTREACH THROUGH STRATEGIC PARTNERSHIPS: AFRICA REGION TRAINING INITIATIVE In 2010 EBC partnered with the Africa Regional Learning Committee and IFC to deliver Living Our Values training to Bank

Group including IFC Country Offi ce staff in Africa. In the fi rst year of the 2-year initiative, EBC undertook 4 training missions, reaching over 500 staff from 15 Africa Country Offi ces. An additional goal of this training was to develop capacity among the Africa HR professionals both in Washington and in Country Offi ces to deliver follow-up ethics presentations and workshops. Training missions to the Region are underway in FY11 to complete this commitment. EBC seeks to build similar partnerships with other regions, networks and VPUs in the future.

92010 report

Training Training in Brazzaville, Republic of Congo Photo: Dieudonne Katende

Train-the-Trainer session in Delhi, IndiaPhoto: Nichola Dyer

Training in Banda Aceh, IndonesiaPhoto: Anne Marie Taylor

IFC training in Dhaka, BangladeshPhoto: Md. Iskandar Arif Chowdhury


EBC works toward this goal by providing staff with advice on fi nancial and other types of confl icts of interest and through the Financial Disclosure Programs, which it administers.

CONFLICTS OF INTERESTA confl ict of interest situation arises when a person or an institution has divergent interests, such as when a staff member’s personal interests are different from those of the WBG. Staff have a duty of loyalty to the WBG and must seek to “avoid situations and activities that might refl ect adversely on the Organizations, compromise their operations, or lead to real or apparent confl icts of interest…” (WBG Principles of Staff Employment, Principle 3).

A confl ict of interest does not necessarily mean a staff member has done something improper. However, promptly disclosing and managing the confl ict is important to avoid potentially serious consequences.

EBC’s website provides information on approaches to handling different types of COI. However, many staff members benefi t from consulting with EBC directly about their personal situations. EBC provides hundreds of consultations each year, predominantly in the areas of outside activities and pre/post-WBG employment (table 2). The fact that so many staff pro-actively approach EBC for advice with queries is a positive indicator of a

rust and TransparencyMANAGING PROGRAMS TO PROMOTE TRUST AND TRANSPARENCY, INCLUDING HANDLING CONFLICTS OF INTEREST AND FINANCIAL DISCLOSURE

THE GOAL OF EBC’S TRUST AND TRANSPARENCY FUNCTION IS TO HELP STAFF IDENTIFY AND MANAGE CONFLICT OF INTEREST (COI) RISK, THEREBY BUILDING STAKEHOLDER TRUST IN THE INSTITUTION.

EBC works toward this goal by providing staff with advice on fi nancial andother types of confl icts of interest and through the Financial DisclosurePrograms, which it administers.

CONFLICTS OF INTERESTA confl ict of interest situation arises when a person or an institution hasdivergent interests, such as when a staff member’s personal interests are different from those of the WBG. Staff have a duty of loyalty to the WBG andmust seek to “avoid situations and activities that might refl ect adversely onthe Organizations, compromise their operations, or lead to real or apparent

MANAGING PROGRAMS TO PROMOTE TRUST AND TRANSPARENCY, INCLUDING HANDLING CONFLICTS OF INTEREST AND FINANCIAL DISCLOSURE

THE GOAL OF EBC’S TRUST AND TRANSPARENCY FUNCTION IS TO HELP STAFF IDENTIFY AND MANAGE CONFLICT OF INTEREST (COI) RISK, THEREBY BUILDING STAKEHOLDER TRUST IN THE INSTITUTION.

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112010 report

high level of ethical awareness among staff.

In providing advice to staff, EBC refers to the applicable Staff Rules, policies, and principles, and applies a stakeholder analytical framework to the specifi c facts of each situa-tion (fi gure 3, page 12). Through this analysis, EBC assists staff members in reviewing who the stakeholders are in a given situation, their interests and how they may diverge, and the risks and benefi ts arising from the situation. EBC team members then provide advice and guidance in response to the staff member’s query to help en-sure that appropriate safeguards

are in place to manage risks, with particular attention to the interests of the World Bank Group.

Currently, average response time for COI guidance is less than 5 days for all consultations, and half of the

Does a gift, proposed activity, or relationship:

■ Affect WBG activities or stakeholders?

■ Affect WBG relations with member countries, with the public, or with other stakeholder groups?

■ Create an impression of WBG or staff bias or partiality?

■ Overlap with my WBG role or responsibilities?

■ Involve WBG time or resources?■ Utilize or result in the disclosure

of WBG nonpublic information?■ Involve others who do, or intend

to do, business with the WBG?■ Violate local law, including visa

regulations?■ Involve remuneration?■ Involve a for-profi t concern?■ Adversely refl ect on the WBG’s

reputation or compromise its operations in any way?

If the answer to any of these questions is “yes,” typically it is advisable for a staff member to seek guidance from a senior manager or EBC.

—World Bank Group Code of Conduct, p. 15

EVALUATING PERSONAL CONFLICTS OF INTEREST

TABLE 2. CONFLICT OF INTEREST CONSULTATIONS BY CATEGORY OVER TIME

Category FY07 FY08 FY09 FY10

Outside Activities 204 295 316 298

Future or Former Employment 68 83 91 99

Close Relatives 46 47 41 74

Business COI 59 74 54 56

External Service/Leave 34 51 54 52

Gifts and Entertainment 26 35 45 36

Relationships/ Spouses 29 36 32 34

Personal Financial Interests 20 22 33 34

Vendor Procurement 49 50 42 31

Medals and Honors 16 16 13 21

Reputational Risk 12 13 34 18

Total 563 722 755 753

% Change from prior FY +13 +28 +5 0

All staff members have a duty to

disclose fi nancial confl icts of interest

as they arise.


FIGURE 3. PROACTIVE CONFLICT OF INTEREST MANAGEMENT PROCESS

FIGURE 4. CONFLICT OF INTEREST CONSULTATIONS: VOLUME AND DAYS TO CLOSURE, QUARTERLY

Stakeholder identifies

possible COI and seeks EBC guidance

EBC helps stakeholderto evaluate:

Applicable rules, policies,principles

Affected stakeholdersand their interests

EBC makes a recommendation to the stakeholder

Stakeholder takes appropriate

action(s) ➔

➔➔

➔

➔➔

EBC CONSIDERS:

■ Do the interests conflict with those of WBG?

■ What are the risks and benefits? ■ What are the appropriate safeguards

and risk mitigation measures?

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Volume of consultations

Median numberof days

Average numberof days

FY06 FY07 FY08 FY09 FY10

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153146 151

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190

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195

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queries received are handled within one day (see fi gure 4). While many COI consultations are rapid and require only brief exchanges, some are complex and lengthy, and may cover extended periods. The spike in average response times that arose in mid-FY07 refl ected acute staffi ng constraints in the unit, coupled with a steadily increasing volume of queries.

The majority of self-reported COI consultations received by EBC relate to outside interests and em-ployment (53 percent in FY10). EBC also provides guidance on close relatives, external service, vendor procurement, and gifts. The Offi ce often partners with other groups to help teams better identify and manage COI risk. Such partnerships might involve the trust fund community,

132010 report

procurement, and legal. In addition to handling personal COI matters for all WBG staff, EBC also is re-sponsible for business COI involv-ing IBRD and IDA. Such queries ac-counted for 7 percent of EBC’s consultations in FY10.

OUTSIDE INTERESTS COMMITTEEMany outside activities that staff members wish to carry out in a pri-vate capacity require notifi cation to and/or prior approval by the Outside Interests Committee (OIC). The OIC provides a forum and a process for determining which outside activities should be permitted. Typical OIC consultations address questions relating to outside entities, awards and honors, board memberships, and seeking public offi ce.

EBC chairs the OIC, and its membership is drawn from repre-sentatives of Human Resources and Legal, staff nominated by the Staff Association, and Bank Group staff at large. Members have renewable 2-year terms and are appointed by HRSVP. Additional details on the OIC and current committee composition can be found in Staff Rule 3.05.

WORLD BANK GROUP’S FINANCIAL DISCLOSURE PROGRAMSIt is good practice for staff mem-bers to assess periodically whether or not their personal fi nancial and business interests could come into confl ict with those of the Bank Group. The WBG’s Financial Disclosure (FD) programs are de-signed to help staff in certain roles fulfi ll that obligation.2 EBC manages

two FD programs: the “Staff Program” and the “Senior Management Team/Vice Presidents (SMT/VP) Program.” It is important to note that all staff, regardless of whether they are required to fi le under either program, must properly manage confl icts of interest.

FD PROGRAMS FOR STAFFSome staff—identifi ed as those at level GH and above, and those with certain roles and responsibilities—are required to fi le an annual disclo-sure. These disclosures are diag-nostic and preventive tools to help staff review their individual situa-tions in light of Bank Group activi-ties and make any needed adjust-ments. EBC administers the pro-gram in accordance with Principle 3 under the Principles of Staff Employment and Staff Rule 3.03.

When the FD program was fi rst established in 2000, 35 senior managers were required to fi le. The program has expanded over time, fi rst to cover Director-level staff (for approximately 200 fi lers), then extended to all GH-level staff members. Additional staff groups have since been designated as fi lers in light of their roles and responsibilities. These include all staff in EBC, INT, and OES, as well as GG-level country managers and certain ungraded staff. In 2010, staff working in GSD Corporate Real Estate and Corporate Procurement also were included. In addition, some staff members in the Carbon Finance unit have par-ticipated on a volunteer basis since 2005. In April 2010, 1,947 staff members were required to fi le.

EXAMPLE

2. Note: There is a separate program for members of the Board of Directors and their staff, which is managed under the auspices of the Board, independently of the staff programs.

I work as a Senior Investment Offi cer and would like to take external service without pay for one year to assist a fi rm in building its capacity. The fi rm does business with the World Bank Group (WBG). May I do so?

Maybe. It will depend on the nature of the assignment, in particular, whether there would be any overlaps with the WBG. You have an obliga-tion to act in the interest of the WBG, which remains your employer. If you have ques-tions about this situation and the related rules, consult your manager and seek assistance from HR or EBC. Note that if the assignment is unrelated to the WBG, it may be possi-ble to accept—but you should, nonetheless, remember that your obligations as a staff member will continue while you are on external service.

— World Bank Group Code of Conduct Q&A Supplement, p. 13.


To promote transparency, the WBG has made FD fi ling mandatory for the designated groups of staff and has imposed a system of graduated fi nes for those who do not fi le in a timely manner. Each year, approxi-mately 10 percent of fi lers have fi led after the April 30 deadline. All fi nes collected by EBC are donated to the WBG’s Community Connections Campaign (CCC). Since 2008, EBC has donated $32,300 in noncompliance fi nes to the WBG’s CCC.

PUBLIC FINANCIAL DISCLOSURE BY SENIOR MANAGEMENT TEAM MEMBERS AND VICE PRESIDENTSThe 2008 World Bank Group Annual Report announced that, for the fi rst time, there would be public disclo-sure of fi nancial and outside inter-ests by the Bank Group’s Senior Management Team. In the spirit and interest of good organizational governance and transparency, the Bank Group’s Senior Management Team agreed to make summaries of its disclosures public. In 2009 many of the Bank Group’s Vice Presidents also elected to make public the summaries of their disclosures. In 2010 this program includes public disclosure for all participants.3

The disclosures fi led by the mem-bers of the Senior Management Team and Vice Presidents, given the breadth of their roles and responsibilities, are more compre-hensive than those fi led under the regular staff program. EBC conducts in-depth reviews and certifi es the disclosures of the Senior Management Team and Vice Presidents. As part of its review and certifi cation, EBC brings issues regarding possible confl icts of interest to the attention of fi lers. The summary disclosure statements are posted on the external website, with the Annual Report, after an accounting fi rm has evaluated the consistency of the summaries with the more detailed internal documents. This engagement is conducted in accordance with standards promulgated by the American Institute of Certifi ed Public Accountants.

“The Bank Group has a fi nancial disclosure program to ensure that any actual, potential, or apparent confl icts of interest arising from staff members’ fi nancial interests, business relationships, other private affi liations or outside activities, or those of their immediate family members, can be identifi ed and managed in the best interests of the Bank Group. Staff members are required to complete and submit their confi dential fi nancial disclosures on an annual basis. EBC administers the program in accordance with Principle 3 under the Principles of Staff Employment and Staff Rule 3.03.”

— Public FD for Senior WBG Managers http://go.worldbank.org/2F4KGYU01

3. In 2010, for security reasons, there will be a single exception to the public disclosure requirement.

“As the leaders of the World Bank Group, we have an obligation to those we serve and those who support our work to maintain

high standards of business conduct.That includes being a model of good governance practices such as transparency.

––Robert B. Zoellick, President

152010 report

“Respond and Resolve” was established with the adoption of Staff Rule 3.00 (SR3.00), effective July 1, 2009, which implemented one of the recommendations of the Volcker Report. SR3.00 transferred responsibility from the Integrity Vice Presidency (INT) to EBC for reviewing allegations for specifi c types of alleged staff misconduct (excluding signifi cant fraud and corruption).

PRIOR TO STAFF RULE 3.00EBC provided guidance, advice, and assistance on a range of business conduct matters but did not conduct investigations. Each consultation with EBC represented a question or concern raised by a staff member, spouse, G5 visa holder, or other interested party about Bank Group rules and policies and how they should be implemented.

EBC provided guidance on misconduct-related concerns, and experi-enced a 39 percent increase in such consultations in FY09 over FY08 (fi gure 5). Additionally, EBC provided guidance on domestic issues, typically involving G5 (domestic employee) matters, domestic abuse, child support payments, and divorce and alimony-related compliance matters. Policy consultations typically involved nonspecifi c queries

espond and ResolveRESPONDING TO AND INVESTIGATING CERTAIN TYPES OF ALLEGATIONS OF STAFF MISCONDUCT

THE OFFICE OF ETHICS AND BUSINESS CONDUCT RESPECTS THE RIGHTS OF ALL PARTIES INVOLVED IN AN ALLEGATION OF WORKPLACE MISCONDUCT—THE VICTIMS, AS WELL AS WITNESSES, AND THE ACCUSED.

“Respond and Resolve” was established with the adoptionRule 3.00 (SR3.00), effective July 1, 2009, which implemenof the recommendations of the Volcker Report. SR3.00 traresponsibility from the Integrity Vice Presidency (INT) to EBreviewing allegations for specifi c types of alleged staff mis(excluding signifi cant fraud and corruption).

PRIOR TO STAFF RULE 3.00EBC provided guidance, advice, and assistance on a rangebusiness conduct matters but did not conduct investigatio

RESPONDING TO AND INVESTIGATING CERTAIN TYPES OF ALLEGATIONS OF STAFF MISCONDUCT

THE OFFICE OF ETHICS AND BUSINESS CONDUCT RESPERIGHTS OF ALL PARTIES INVOLVED IN AN ALLEGWORKPLACE MISCONDUCT—THE VICTIMS, AS WWITNESSES, AND THE ACCUSED.

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about rules, procedures, or their application in practice.

Other areas in which EBC assisted staff involved interpersonal confl icts, employment decision-related concerns, management skills and behavior, and retaliation. EBC worked to facilitate informal resolu-tions. It referred misconduct mat-ters requiring investigation to INT.

THE RESPOND AND RESOLVE FUNCTIONAllegations of staff misconduct handled by EBC after the adoption of SR3.00 include but are not limited to workplace grievances, such as hostile work environment, discrimination, sexual harassment, or retaliation; noncompliance with personal legal obligations, such as tax matters, domestic matters, or garnishments; fraud associated with travel, petty cash accounts, P-card, benefi ts, or allowances; and whistleblower retalia-tion matters as defi ned in SR8.02.

EBC’s Respond and Resolve function is so named in recognition that staff concerns sometimes are best addressed through a resolution process that does not involve formal fact-fi nding and/or disciplinary proce-dures. It often is possible for people to work together directly to resolve concerns in a way that is both more expedient and brings about better and more durable outcomes.

As set forth in SR3.00, EBC can implement a range of approaches to case resolution (see examples). Based on the specifi c facts of each case and EBC’s Initial Review, options include:

FIGURE 5. CONSULTATIONS, FYO7-FY09(EXCLUDING CONFLICT OF INTEREST CONSULTATIONS)

0 20 40 60 80 100

RETALIATION

OTHER

MANAGEMENT SKILLSAND BEHAVIOR

EMPLOYMENT/ASSIGNMENTISSUES

COMPLIANCE ISSUES

POLICY

INTERPERSONAL CONFLICT

DOMESTIC ISSUES

MISCONDUCT

FY09FY08FY07

5367

93

26

74

44

19

2010

87

11

89

9

23

5

9

10

10

12

15

2231

Situation: An interpersonal confl ict arose between two staff members in a Country Offi ce due to tension related to work projects. One person was alleged to have created a hostile work environment for the other—and this tension impacted others in the offi ce. The manager was notifi ed by the staff member who felt harassed. The manager, in turn, contacted EBC.

EBC’s Approach: EBC arranged for an initial discussion with the manager to determine the nature of the alleged confl ict. EBC assessed that the issues in the group did not rise to the level of misconduct but, rather, refl ected a breakdown in communication. EBC provided the manager with options, including referring the two staff members to Mediation Services. A conference call was facilitated among all parties to discuss the matter. The managers for both staff members asked for a written follow-up that would include guidance on specifi c issues as well as ways to address them before they escalated. EBC provided a written response and requested that the managers provide a status update to EBC.

Outcome: Management provided the staff members with additional coaching, guidance, and instructions. The matter was resolved, and no further assistance was requested.

Duration of case: 12 days.

EXAMPLE 1: INFORMAL RESOLUTION

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Referral to an appropriate depart-

ment for resolution, such as the Confl ict Resolution Services or Human ResourcesAgreeing to a binding resolution

between the WBG and staff memberConducting a fact-fi nding to

investigate an allegation of misconduct

EBC conducts its initial reviews and fact-fi ndings according to interna-tionally recognized best practices, procedures, and protocols. To en-sure that the most appropriate unit is handling the concern, cases can be referred by EBC to another ser-vice or unit at any point. The pro-cess used by EBC with respect to an allegation of misconduct involves the following procedural stages:1. Upon receiving an allegation or

concern, EBC assesses wheth-er the issues fall under EBC’s jurisdiction.

2. If so, EBC conducts an initial review and determines whether there is suffi cient factual basis to warrant further consider-ation. In the affi rmative, EBC continues its investigation pro-cess with a fact-fi nding.

3. The staff member who is the subject of the allegation (“sub-ject”) receives a Notice of Alleged Misconduct laying out the allegations. The subject is requested by EBC to attend an interview to seek his/her re-sponse to the allegations of misconduct. The subject also has the right to respond to the allegations in writing within fi ve business days from the date of the interview.

Situation: A staff member notifi ed a manager of alleged ongoing sexual harassment. The manager, as required, contacted EBC for a meeting to ascertain how to proceed.

EBC’s Approach: A meeting was scheduled the day after the initial intake by EBC. Based on the interview, an initial review was planned and undertaken. Advice was provided—and implemented—to separate the staff members pending a pre-planned reassignment of the alleged harasser. Corroboration from four witness interviews provided justifi cation for a formal fact-fi nding. Based on the decision to investigate, a Notice of Alleged Misconduct was sent to the alleged harasser, and a fact-fi nding undertaken.

Outcome: The allegations were substantiated by the fact-fi nding, and EBC issued a report on the matter to HRSVP for a decision on appropriate disciplinary measures.

Duration of case: 7 months.

EXAMPLE 2: FORMAL RESOLUTION THROUGH FACT-FINDING

4. If, at the conclusion of the fact-fi nding, EBC recommends that the matter be addressed through the imposition of one or more disciplinary measures, the sub-ject will be provided with a writ-ten summary of the fact-fi nding (“fi nal report”). The subject is giv-en fi ve business days to respond in writing. These comments are reviewed by EBC to determine whether they warrant any modifi -cation to the fi nal report. The re-port, along with the complete and unaltered comments by the subject, are then submitted to the Vice President of Human Resources for a decision on the fi nding of misconduct and the discipline to be imposed.

CASE DATAIn FY10, the fi rst year of the Respond and Resolve (R&R) Function, EBC received 284 intakes (table 3). Of these, 202 were classi-fi ed as allegations or “cases” of misconduct (table 4).

The majority of FY10 misconduct cases opened by EBC fell into 4 categories: Personal Legal Obligations (29 percent); Harassment (20 percent); Staff Rule 3.01–3.06 violations (15 percent); and Abuse of Power (12 percent) (table 4). The cases arising in these categories account for 76 percent of total misconduct cases opened. Some of these matters may arise from a lack of information or under-standing of the WBG’s expectations or requirements. Increased educa-tion of staff may help prevent such issues in the future. To this end, EBC is targeting additional training and outreach in these four areas.

EBC has a well-established coopera-tion with its partner units. It has referred 14 percent of intakes to other appropriate Internal Justice System units, including to INT and the Confl ict Resolution System. Of intakes received in FY09–104 that were subject to Staff Rule 3.00,

194 were closed (tables 6 and 7).

4 In FY09, prior to SR3.00 taking effect, due to changes in Staff Rule 8.01, 25 personal legal obligations cases were received. These cases are not refl ected in FY10 intake data but do impact the case closure data.


The most frequent outcome was the provision of advice by EBC (56 instances, or 29 percent). These 56 included 20 allegations of miscon-duct that subsequently were deter-mined not to be misconduct. The provision of advice by EBC was de-signed to provide a staff member with options on how to proceed and resolve the underlying issues.

Additionally, at their initial review stage, a signifi cant number of in-stances (36 cases, or 29 percent of total misconduct case closures) were determined to contain insuffi cient evidence on which to proceed and/or to be based on unfounded allega-tions. As the volume of cases in-creases, EBC is analyzing the intake data to help staff better understand the process and the requirements for proceeding with a fact-fi nding.

A matter of concern is the number of clients (24 of the 194 closed cases) who withdrew their allega-tions upon learning that, through the issuance of a Notice of Alleged Misconduct, their identities or other details might become known to the subjects. Despite EBC’s assurances of the Bank Group’s protections from retaliation, this fear of disclosure may have had a chilling effect on the number of cases that resulted in recommen-dations of formal disciplinary measures.

The EBC Scorecard articulates the next steps or “the road ahead” with respect to the Respond and Resolve function (page 24).

Situation: A manager contacted EBC to request assistance with respect to alleged inconsistencies relating to inventory, cash account, and merchandise returns. The manager suspected that someone was fraudulently manipulating the systems and that this behavior had been ongoing for several months.

EBC’s Approach: EBC met with the manager as part of the initial intake. EBC subsequently coordinated with Security Operations to assess the evidence that was available for the initial review. EBC proceeded with interviews and an independent review of the facts and evidence, which enabled EBC to corroborate the allegations. These actions resulted in EBC sending a Notice of Alleged Misconduct to the staff member who was the subject of the investigation. An interview was scheduled to obtain additional information concerning the alleged misconduct directly from the suspected staff member. The suspected staff member was placed on administrative leave pending the outcome.

Outcome: EBC presented the staff member with a binding resolution and voluntary resignation option to address the needs of all parties involved. The staff member accepted, resigned, and agreed to restitution. The agreement precludes the staff member from future employment in the World Bank Group.

Duration of case: 4 weeks.

EXAMPLE 3: FORMAL APPROACH THROUGH BINDING RESOLUTION

TABLE 3. RESPOND AND RESOLVE INTAKES OPENED BY CATEGORY, FY10

Category Intakes

Misconduct (see breakdown in table 4) 202

Management Skills and Behavior 21

Employment/Assignment Issues 18

Interpersonal Confl icts 15

Domestic Issues (G5 Employees, Domestic Abuse) 13

Policy 12

Other (non-WBG-related allegations) 3

Total 284

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TABLE 4. MISCONDUCT CASES OPENED BY ISSUE, FY10

Issue Cases

Personal Legal Obligations (loans, alimony, liens, G5)* 58

Harassment (all forms) 40

Violations of Employment Principle 3/ SR3.01-3.06 (unmanaged confl icts of interest) 30

Abuse of Authority/Position 25

Misuse of Bank Resources (compensation/travel) 12

Misuse of Bank Assets (incl. IT, email) 7

False Reporting 6

Discrimination 6

Retaliation 4

Corruption/Bribery/Kickbacks** 4

Information/Data Protection 3

Theft 2

Convictions for Criminal Actions 2

Unprofessional Conduct/Negligence 2

Other 1

Misconduct Total 202

Intakes that fell into categories other than misconduct were often referred by EBC to managers for resolution, addressed through providing guidance,or referred to other appropriate units within the Internal Justice System (Table 5 shows cases closed by these means).

Note: *In addition to the misconduct cases received by EBC in FY10, 25 personal legal obligations cases were received in FY09 due to changes in SR8.01that occurred prior to SR3.00 taking effect.** Referred to INT for investigation.


TABLE 5. FY10 MISCONDUCT CASES BY STATUS AND OUTCOME

Number of cases Category Action taken

202 Misconduct Advised (20)

Withdrawal of allegation by client (12)

Fact-Finding—Insuffi cient evidence/allegations unfounded (6)

Initial Review—Insuffi cient evidence/allegations unfounded (36)

Mutual Agreement/Options Letter (2)

Referred (18)

Submitted to HRVP for decision on discipline/fl ags (5)

Resolved—No action necessary (6)

Resolved informally after EBC intervention (21)

Open (76)

21 Management Skills and Behavior Advised (4)


Referred (6)


Open (8)

18 Employment/Assignment Issues Advised (9)


Referred (1)

Resolved—No action necessary (3)


Open (3)

15 Interpersonal Confl icts Advised (8)


Initial Review—Insuffi cient evidence/allegations unfounded (1)

Referred (1)

Submitted to HRVP for decision on discipline/fl ags (1)


13 Domestic Issues Advised (4)


Referred (1)


Open (1)

12 Policy Advised (9)

Referred (1)

Open (2)

3 Other Advised (2)

Referred (1)

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TABLE 7. MISCONDUCT CASES CLOSED BY OUTCOME, FY10

Outcome Cases

Initial Review—Insuffi cient evidence/allegations unfounded 36

Resolved informally after EBC intervention 21

Advised 20

Referred (to INT, Confl ict Resolution System) 18

Withdrawal of allegation by client 12

Resolved—No action necessary 6

Fact Finding—Insuffi cient evidence/allegations unfounded 6

Referred to HR for Disciplinary Proceedings or Flags 5

Options Letter/Mutual Agreement and Rehire Flag 2

Total 126

TABLE 6. INTAKES CLOSED (EXCLUDING MISCONDUCT) BY OUTCOME, FY10

Outcome Intakes

Advised 36

Withdrawal of allegation by client (including anonymous allegations with no follow-up after prompt) 12

Referred (to Management, HR, Confl ict Resolution System) 11

Resolved informally after EBC intervention 5

Resolved—No action necessary 3

Referred to HR for Security Flag 1

Total 68


TREND ANALYSISThe KM function produces analyses that are shared with senior management, Internal Justice System partners, and other stakeholders based on:

Feedback on concerns––or knowledge gaps––voiced by staff who participate in EBC-sponsored outreach and training sessions Number and types of confl ict of interest consultations that are brought to EBC’s “Trust and Transparency” functionTrends of allegations of staff misconduct that are brought to EBC’s “Respond and Resolve” function

EBC shares lessons learned to help educate staff and refi ne EBC’s internal process, as well as to deter and detect staff misconduct. This information-sharing is designed to strengthen WBG policies, procedures, and business practices. Safeguards are in place, and care is taken to protect the privacy of individuals who approach EBC. Case trend-related information does not contain personally identifi able information that can be linked to individual cases or inquiries. Aggregation also is used to protect confi dentialty.

nowledge ManagementTRACKING TRENDS AND PROVIDING INSIGHTS TO SENIOR MANAGEMENT

THE GOAL OF THE KNOWLEDGE MANAGEMENT (KM) FUNCTION IS TO ENSURE THAT THE INSIGHTS DERIVED FROM EBC’S OUTREACH, ADVISORY SERVICES, FACT-FINDINGFUNCTIONS, AND ETHICS SURVEY ARE USED TO BENEFIT THE INSTITUTION.

TREND ANALYSISThe KM function produces analyses that are shared with senio

TRACKING TRENDS AND PROVIDING INSIGHTS TO SENIOR MANAGEMENT

THE GOAL OF THE KNOWLEDGE MANAGEMENT (KM) FUNCTIS TO ENSURE THAT THE INSIGHTS DERIVED FROM EBC’S OUTREACH, ADVISORY SERVICES, FACT-FINDFUNCTIONS, AND ETHICS SURVEY ARE USED TO BETHE INSTITUTION.

K

232010 report

In addition to tracking issue-relat-ed trends, EBC keeps statistics on the ways in which staff contact the Offi ce. As the WBG further decentralizes, it is especially important to ensure that resources such as EBC remain easily accessible to Bank Group staff worldwide. Table 8 shows an analysis of the points of entry used by staff to contact EBC. These entry points refl ect all types of queries. Tracking such statistics enables EBC to periodi-cally reevaluate its contact chan-nels to ensure that they are meet-ing the needs of all staff groups.

ETHICS SURVEYIn September 2008, EBC conduct-ed the World Bank Group’s fi rst comprehensive Ethics Survey. The objective of this survey was to es-tablish a baseline of staff knowl-edge and perceptions of business conduct before fi nalizing the re-vised Code of Conduct and the Living Our Values training initiative for all staff.

The survey was sent to 2,446 randomly selected Bank Group staff worldwide (including consultants), a group representa-tive of WBG demographics. The total number of respondents was 1,091 (44.6 percent response rate). EBC has used the survey fi ndings to refi ne its training programs, and fi ndings were shared with senior management. A detailed summary of the fi ndings is available on the EBC intranet website (http://ethics).

Based on the Ethics Survey fi ndings, EBC has developed tailored training programs and updated the Code of Conduct. The survey will be readministered in 2011 and used to benchmark the institution’s progress on the issues that were identifi ed in the 2008 survey and evaluate the impact of the program.

TABLE 8. METHOD OF ACCESSING EBC—TOTAL QUERIES AND BY %

FY 2007 FY 2008 FY 2009 FY 2010

Total queries 631 759 853 1,005

Breakdown by %

Email 67.2 66.8 51.2 50.5

Telephone 19.0 17.7 23.8 21.2

Helpline (Email) 5.9 8.7 13.0 15.6

Helpline (Phone) 2.5 1.3 5.0 5.0

Letter 0.5 0.9 0.5 3.0

Walk-In 0.5 1.6 2.8 1.8

Meeting 2.9 2.1 1.5 1.3

Fax 0.5 0.4 0.1 0.5

Other 1.0 0.5 2.1 1.1

■ Most staff (85%) feel preparedto handle business conduct situations.

■ More than three-quarters of staff (76%) had not observed any ethical violations in the preceding 12 months.

■ Half of staff (51%) and two-thirds of managers (66%) seek guidance most of the time as to the appropriate ethical or legal course of action.

■ Over half (55%) of staff felt their managers would support them if they raised a concern.

■ A few pressure points exist:● Staff felt that more senior

staff were less likely to be held accountable than the staff’s coworkers/peers.

● The survey exposed signifi cant gaps in knowledge regarding the handling of a range of hypothetical busi-ness scenarios. Responses indicated that many staff were unaware of the most appropriate responses to certain situations, including which unit(s) were the most appropriate to resolve theissues involved.

● One-third of staff would not seek guidance on the appropriate course of action for ethical situations. The top reasons given for not seeking guidance were con-cerns around confi dentiality, retaliation, and lack of clarity on who had authority to inter-vene on the situation.

LOOKING BACK: 2008 ETHICS SURVEY HIGHLIGHTS


GOALS IN 2008 MILESTONES THE ROAD AHEAD

Update World Bank Group Code of Conduct

November 2009: New global Code of Conduct and mandatory Code e-learning launched

Develop web-based Code with a search option (in progress)

Translate Code into 9 languages (in progress)

Reach 100% staff compliance incompleting Code e-learning

Build robust ethics training program that refl ects best practices in global organizations

Face-to-face training curriculum developed and rolled out to intact work groups (TRE, GSD) in FY09–10

Training developed for managers and HR professionals in 2009

FY10 AFR strategic partnership launched

December 2009: Confl ict of Interest (COI) induction session delivered to Executive Directors

Broaden and deepen outreach, including:

Develop additional e-learning modules (in progress)

Forge new strategic training partnerships with other regions, VPUs, and IFC

Deliver training to all managers and senior managers

Implement one of the Volcker recommendations: to transfer workplace misconduct investigations (excluding signifi cant fraud and corruption) to an “administrativeunit [that] is properly organized and staffed….”

Staff Rule 3.00 developed and implemented (July 1, 2009), expanding EBC’s mandate to include an investigative function

Investigative function staffed (in progress)

Enhance Staff Rules and policies based on learning and experience

Refi ne policies and procedures

Produce Guide to Staff Rule 3.00for staff and managers

Develop tools for managers to prevent and handle misconduct

Strengthen the Financial and Outside Interests Disclosure (FD) program to identify and manage COI risk

2010: Public posting of senior man-agement FD summaries for 3 years

2010 electronic fi ling introduced for senior management

Review process strengthened to sharpen focus on COI identifi cation, including outside interests, while improving fi ler experience

Increase collaboration with operational VPUs to help identify early and manage proactively COI risk, whether personal or business

Establish metrics to measure and benchmark progress

September 2008: WBG’s fi rst Ethics Survey administered

Re-administer survey to benchmark progress

Establish/expand metrics for EBC’s four strategic business lines

ScorecardFOR EBC

252010 report

CONFIDENTIALITY PROTECTIONSConfi dentiality is extremely important in the conduct of an investigation. The substance of an inquiry and/or the identity of staff members are disclosed only on a need-to-know basis. Staff members have the option of raising concerns or allegations anonymously. However, no action can be taken based on anonymous allegations unless they can be independently substantiated. Therefore, these cases may be closed due to insuffi cient evidence or a lack of independently corroborated evidence.

RETALIATION AND WHISTLEBLOWER PROTECTIONSRetaliation undermines trust among staff members as well as between staff and management. It can have a debilitating effect on morale and workplace productivity. Retaliation in the workplace can encompass a range of behaviors. Staff who report suspected misconduct that may threaten the operations or governance of the Bank Group are protected by the Bank Group’s whistle-blowing

aising a concern

TO PREVENT OR MINIMIZE THE DAMAGE ARISING FROM BUSINESSCONDUCT ISSUES, STAFF MEMBERS ARE ENCOURAGED TO ASK QUESTIONS, SEEK ADVICE ABOUT THEIR CONCERNS, AND BRING FORWARD OBSERVED WRONGDOING. STAFF MEMBERS PLAY A CRITICAL ROLE IN RAISING ISSUES AND CONCERNS, HELPING THE WBG TO BETTER IDENTIFY, ADDRESS, AND DETER MISCONDUCT.

CONFIDENTIALITY PROTECTIONSConfi dentiality is extremely important in the conduct of aninvestigation. The substance of an inquiry and/or the identof staff members are disclosed only on a need-to-know baStaff members have the option of raising concerns or alleganonymously. However, no action can be taken based on aallegations unless they can be independently substantiatedTh f th b l d d t i ffi i t

TO PREVENT OR MINIMIZE THE DAMAGE ARISING FROM BCONDUCT ISSUES, STAFF MEMBERS ARE ENCOUASK QUESTIONS, SEEK ADVICE ABOUT THEIR COAND BRING FORWARD OBSERVED WRONGDOINGMEMBERS PLAY A CRITICAL ROLE IN RAISING ISSAND CONCERNS, HELPING THE WBG TO BETTERADDRESS, AND DETER MISCONDUCT.

R


Contacting EBC

Tel: 202-473-0279

Fax: 202-522-3093

Ethics Helpline: 800-261-7497

(24 hours 7 days a week)

[email protected]

Intranet: http://ethics

Internet: http://www.

worldbank.org/ethics

The more specifi c the information that you provide, the better EBC will be able to follow up on your allegation. Include details such as:

■ What alleged wrongdoing you are reporting and whether anyone else has witnessed or experienced the alleged wrongdoing

■ Where and when (dates and times if available)

■ Who is involved or may have committed misconduct

■ How the alleged wrongdoing was committed

■ How you can be reached for more information or clarifi cation

protections (see Staff Rule 8.02). This rule expressly prohibits managers or other staff from retaliating in any form against any staff member who has reported suspected misconduct or cooperated or provided information during an investigative process. Staff should be assured that anyone who brings concerns forward in good faith will be protected from retaliation.

WBG staff should feel comfortable in openly raising business conduct questions and concerns. Asking a question early in the process often can prevent serious consequences.—Code of Conduct, page 35

EBC Team 2010

272010 report

Photo: Deborah Campos

Our Core ValuesWORLD BANK GROUP

● Personal honesty, integrity, commitment

● Working together in teams—with openness and trust

● Empowering others and respecting differences

● Encouraging risk-taking and responsibility

● Enjoying our work and our families

OFFICE OF ETHICS AND BUSINESS CONDUCTTEL: 202.473.0279 FAX: 202.522.3093EMAIL: [email protected] HELPLINE : 800.261.7497 (24 HOURS 7 DAYS A WEEK)INTRANET: HTTP://ETHICS.WORLDBANK.ORGINTERNET: HTTP://WWW.WORLDBANK.ORG/ETHICS

THE WORLD BANK GROUP1818 H Street N.W. Washington, D.C. 20433

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