28 MAY 2009
Global Transparency Initiative (GTI) Comments on World Bank Disclosure Proposal, Offers Model Policy

The Global Transparency Initiative (GTI) has filed comments critical of World Bank’s preliminary proposal to rewrite its disclosure policy and also suggested a “model policy” alternative. Despite praising the Bank’s movement toward a system more like good national right-to-know statutes, the GTI identified “a number of shortcomings” in the “approach paper” advanced by the Bank. The GTI is a network of civil society organizations promoting openness at the international financial institutions.

The approach paper was the basis for a consultation period with the Bank aiming to approve a new disclosure policy this summer. June 5 is the new deadline for comments and the Bank is continuing a series of listening sessions around the world on its proposals. The GTI comments on the approach paper go into detail about the Bank’s proposals.

The GTI’s “model policy” is based on the its 2006 Transparency Charter for International Financial Institutions. The model policy, however, gets into more specific issues and attempts to address World Bank operations particularly.

Bank Proposal Called Too Broad

The Bank has proposed to follow the principle that most documents should be disclosed, subject to stated exceptions, but the GTI called the suggested exemptions “overly-broad.”

“Most of the exceptions proposed in Section C of the Approach Paper do not refer to specific interests that might be harmed. Instead, they describe either a category of documents (e.g., Board records or being part of the external or internal deliberative process) or a process (being classified as `official use only’ or being subject to third party consent),” according to the GTI comments.

“We call on the Bank to revise the proposed exceptions to reflect a true `harm test.’”

GTI continued, “Furthermore, the policy should make it clear that exceptions only apply to specific information the disclosure of which would lead to harm. Instead of rendering whole documents off limits, exceptions apply only to specific information contained in documents, which may then be redacted and the rest of the document released. Together, these problems seriously undermine the idea of a presumption of disclosure.”

Among other things, the GTI objected to giving third parties, such as contractors and member countries, “a veto over release of information they have provided to the Bank.”

The GTI model policy offers a series of exemptions from disclosure.

GTI also noted that certain key aspects of a future disclosure picture are murky because the Board of Executive Directors is still studying key issues. These include such GTI requests as access to materials sent to it for consideration, the so-called “draft” documents that include Bank staff’s recommendations for action.

Regarding other elements of the proposals in the “approach paper,” the GTI found a “lack of detail” concerning plans to process requests for information and criticized the lack of an independent appeals body. In its proposed model policy, GTI suggested that the Bank’s existing Independent Review Panel could play that role.

In addition, the GTI urged the Bank to translate more materials, strengthen the Bank’s Public Information Centers, and actively promoting access to information.

By Toby McIntosh

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