On April 13, 2009, the Yemen Observatory for Human Rights, a civil society organization based in Sana’a, officially submitted their case regarding the World Banks translation framework to the World Bank Inspection Panel.
The forthcoming case is the culmination of the Banks rejection of repeated requests by Yemeni civil society groups to translate a key World Bank document, highlighting chronic problems with the Banks policy on document translation as well as its requests and appeals mechanisms.
The Yemeni group is taking its complaint to the Inspection Panel, established in 1993 to address the concerns of the people who may be affected by Bank projects and to ensure that the Bank adheres to its operational policies and procedures during design, preparation, and implementation phases of projects.
Although English is the official language of the Bank, it routinely translates general information and its flagship publications into Arabic, Mandarin, French, Portuguese, Russian, and Spanish, as a matter of best practice rather than policy. However, for projects, borrower governments alone bear translation responsibilities, and, as a result, these translations are quite limited in scope (such as summaries of environmental assessments and plans related to resettlement or indigenous peoples). Additionally, project information that is translated is difficult to locate. Core Bank documents such as Project Appraisal Documents (PADs) or Program Documents (PDs), such as those for development policy loans, are rarely translated.
The controversy involves a three-year $51 million grant to the government of Yemen designed to support non-oil growth and strengthen governance and public financial management. The Banks initial disclosure concerning the effort has been standard and minimal.
The Banks disclosure policy allows for the release of various documents depending upon the specific stage and type of the project. The disclosure policy stipulates that a Project Information Document (PID) should be released during the concept stage of a project, preceding Board approval. It is usually only a few pages long and the entirety of contents within the PID may or may not necessarily be included in the final approved project. In other words, the publicly released documents preceding approval may not actually represent what the project will look like after approval. Thus, civil societys understanding of what a given project will look like once it has been approved may not be based on complete information. A Project Appraisal Document (PAD) is usually a hundred pages or so, and the disclosure policy mandates that it be released to the public only after a loan, credit, or guarantee has been approved at the Board level. A Program Document (PD) is prepared for adjustment operations financed by the Bank, such as structural adjustment loans and credits, rehabilitation loans, and sector adjustment loans and credits. Any Program Document other than a PRSC (Poverty Reduction Support Credit, released after Board approval), can be made public only after it has been both approved by the Board and has been given consent for release by the borrower.
On December 6, 2007, the World Banks Board of Directors approved the Institutional Policy Reform Development grant for Yemen, although it was not until December 11th that the 80-page Program Document (PD) was posted on its website. Though dated April 2007, the PID, consisting of a mere 6-page summary of the program, was not posted until on December 12, 2007, after the posting of the PD and after the grant had been approved by the Banks Board of Directors. The chronology of these events is in clear violation of the Banks information disclosure policy, as it stipulates that a PID is to be released before project approval and that a PD is to be released immediately following the Boards approval of a given project. Furthermore, the project was never listed on the proposed projects list prior to Board approval.
As the Banks policy states, the PID is prepared when the first formal review of the proposed operation is held by Bank management, and is made publicly available. As project preparation evolves, the PID is updated. The updated PIDs are also publicly available.
The lack of access to pertinent project documentation prior to its approval is a major obstacle to civil society participation. Unfortunately, this is the rule rather than the exception. Project information that is released before approval is often not kept up to date, and, although environmental and social assessments are disclosed before approval, the Bank withholds complete descriptions of projects and programs (Program Document/Project Appraisal Document, PAD) until after approval. The lack of publicly available information prior to project/program approval is a consistent concern of development and transparency activists.
According to the World Bank translation framework, the translation of any program or project-related document is left up to the country managers discretion. Since not all officials in borrowing countries are fluent in English, it may be safe to assume that many of these documents are procedurally translated into the local languages. However, the Bank does not require the government to then submit these translated documents along with the English documents, which would then automatically be publicly disclosed upon receipt by the Bank. Requiring disclosure of the already translated documents would greatly increase access to information at no cost to the World Bank.
On January 16, 2008, a group of civil society organizations submitted a formal request for the project document for the Institutional Policy Reform Development grant to be translated into Arabic. The manager of the Yemeni World Bank office replied on January 20th thanking these organizations for their interest and high level of awareness of the development process in their country and summarily stated that like all other project documentsit is available only in English, since this is the official language to be used in all the transactions and contracts between the Government of the Republic of Yemen and the World Bank. He apologized for not being able to translate the document due to other commitments, although he hoped that the civil society groups could translate it themselves.
On January 30, 2008, civil society leaders again submitted a request to the Yemen country manager to revisit his translation policy, with 25 local organizations signing on in support. The civil society groups specifically stated that:.
Civil society organizations understand quite well the importance and the volume of the role the World Bank is playing in the economic reform and integrated and sustainable development processes, including the projects posted on its website in the field of education, port cities, irrigation, energy, public works, and localities. However, we stress that posting those projects only in English limit excessively our ability to participate effectively and actively.
While civil society organizations understand what you mentioned in your previous letter regarding the difficulties you face in translating projects and documents into Arabic, we still hope that you would kindly apply the measures that ensure the transparency and accessibility to those program documents, especially by providing us with the Institutional Reform Program in Arabic This will definitely reinforce the partnership between us in sharing the responsibility and performing our expected role towards the present causes and future challenges facing our country.
By Rebecca Harris
Bank Information Center
Filed under: IFTI Watch