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Regional Development Banks
The International Program works to strengthen accountability measures in intergovernmental organizations, and the regional development banks represent an important dimension of multilateral grants and loans. Because the Asian Development Bank, the Inter-American Development Bank, the African Development Bank and the European Bank for Reconstruction and Development all enjoy sovereign immunities in the countries where they operate, staff, contractors and vendors need the same whistleblower protections that other, larger international institutions should provide.
In July 2004, GAP released surveys assessing policies purported to protect whistleblower programs at several Multilateral Development Banks (MDBs). Unfortunately, GAP found that all MDBs studied require significant improvements before GAP can responsibly recommend that whistleblowers rely on each bank's internal system to prevent retaliation. The full GAP report, Challenging The Culture of Secrecy: A Status Report on Freedom of Speech at the Multilateral Development Banks, details each bank in full. The links below focus on specific institutions:
Asian Development Bank [ Executive Summary | Full Report ]
European Bank for Reconstruction and Development [ Executive Summary | Full Report ]
Inter-American Development Bank [ Executive Summary | Full Report ]
World Bank [ Executive Summary | Full Report | Oversight Memo ]
In the intervening years, whistleblower protection systems have registered significant advances at the regional development banks. In 2007, the African Development Bank adopted a new policy that defines retaliation as misconduct and provides broad coverage for internal reports of fraud and corruption. Click here to read GAP's review of the policy. The Asian Development Bank passed a new and improved whistleblower protection policy in 2009, after conducting an in-depth public consultation. The policy incorporates several recommendations made by GAP during the consultation phase. Click here to read GAP’s review of the final policy. The Inter-American Development Bank passed a new whistleblower policy in 2010 and then revised it in 2012.
All of these institutions, however, lack a meaningful forum for the adjudication of a complaint of retaliation. Thus far, none of them has provided a whistleblower who has suffered retaliation access to an independent, external judicial forum or to external arbitration. Complaints are heard in an office or before a grievance panel that consists of employees of the same institution, people who can be, and often are, subject to intimidation or influence by management. A structural conflict of interest taints these proceedings. While the regional development banks, and particularly the African Development Bank, allude to the possibility of alternative dispute resolution, in practice they have not gone beyond allowing mediation by a third party chosen from a roster of mediators that is, in turn, compiled by management.
GAP continues to work with the regional development banks to improve and strengthen both their policies and their internal justice systems. Our goal is to provide whistleblowers with a safe channel for reporting corruption as well as a fair forum for seeking relief from retaliation.