Revise guidelines, instruments, and incentives to strengthen supervision arrangements. The World Bank should: Assign responsibility and budget for safeguards oversight and reporting to environmental and social units in each operational regionin line with IFC practicein place of the delegation of safeguards processing and supervision to sector management units. Introduce a certification program to expand the pool of staff qualified to undertake social and environmental preparation and supervision while ensuring quality and consistency, and provide orientation training on environmental and social sustainability to all task team leaders. Develop and implement an action plan to ensure regular supervision of FI projects and investment projects that use social and environmental policy frameworks through third party or community monitoring for higher-risk projects, and disclosure of monitoring and supervision reports.
Original Response: 7.3.a) Disagreed. Bank Management agrees with IEG that there is a need to strengthen supervision of medium- and low-risk projects. How this will be done may need to differ from region to region, depending on country capacity and project type and mix. Bank Management does not agree with the specific recommendation on giving the responsibility and budget for safeguard oversight and reporting to environmental and social units in each operational Region and this will need to be dropped from further monitoring by IEG. Bank Management plans to undertake a review by the second quarter of fiscal 2011 concerning current practices with respect to responsibility, accountability, incentives, staffing, and budgeting for safeguard processing and supervision. This review will also cover the issue of financial intermediary projects and projects that use environmental and social policy frameworks (see below). Based on this review, practices will be updated with the objective of enhancing effectiveness and efficiency and maximizing the synergies between safeguard work and broader Bank engagement on environmental and social sustainability. Timeline: Bank Management action, based on the review, by the third quarter of fiscal 2011. Bank Management notes that, as part of Investment Lending Reform process, it has actions ongoing to enhance the effectiveness and efficiency of implementation support. These include: (a) the assignment of staff and budget in line with the level of risk associated with an operation, using the new risk assessment and management procedures; and (b) the embedding of grievance redress mechanisms more broadly into projects. 7.3.b) Agreed/Ongoing. OPCS is developing, in coordination with SDN and LEG, a mandatory Operational Core Course for task team leaders which includes modules on safeguard policies and their implementation. Bank Management also has several ongoing and planned initiatives to expand the pool of qualified environmental and social staff that can provide support on safeguards and sustainability issues. Bank Management supports the initiation of a certification/ accreditation program for environmental and social staff working on sustainability and safeguard issues starting in fiscal 2011. SDN is working on the design of a core environmental and social sustainability and safeguards course, which will act as a mentoring and certification/ accreditation program for environmental and social staff, selected staff of other sectors, and safeguard consultants. The certification/ accreditation program will commence by the end of fiscal 2011. SDN also has launched several complementary initiatives to improve the staffing and skills mix for sustainability and safeguards, and to align incentives with the mainstreaming of environmental and social sustainability throughout the portfolio. These include: (a) a Bank-wide analysis of staffing for environmental and social sustainability and safeguards; (b) the development of competencies that emphasize skills in sustainability and safeguards, on both the environment and social issues; (c) consistent management signaling regarding the importance of working on sustainability and safeguards; and (d) the organization of field-based training sessions on sustainability and safeguards. Timeline: Processes in place (subject to cost considerations) by the beginning of fiscal 2012 7.3.c) Agreed/Ongoing. Bank Management is currently engaged in a Bankwide review of the use of frameworks that will examine these types of projects and identify good practices. The review will include an examination of a variety of means to strengthen monitoring of such projects, including, in appropriate situations, the use of third-party or community monitoring for selected higher-risk projects. The review is expected to be completed by the third quarter of fiscal 2011 and will provide the basis for guidance to be issued for use by Bank staff and borrowers by the fourth quarter of fiscal 2011.
IEG recognizes that a number of Management actions to improve the application, implementation, and supervision of safeguard related activities are being taken with a view to improving the quality of projects through both upstream preparation and downstream supervision. As demonstrated by the Internal Audit Department (IAD) review, and as pointed out in IEGs 2013 and 2014 MAR response however, there remain unresolved issues related to the stock and available flow of qualified and accredited safeguard staff, who can be adequately assigned in a timely way to projects of different safeguard categories,(including projects with substantial risk. While recognizing the significant efforts launched to recruit and train safeguard staff, IEG also pointed to the need to sensitize task team leaders on the policy and the new guidance.
Disagreed. Management assesses risk, including that related to environmental and social impacts of Bank-funded projects, through the newly introduced Systematic Risk-rating tool (SORT). A specific approach to risk assessment is also proposed in the second draft Environmental and Social Framework (ESF).
SORT assesses risks to development results associated with the operation or CPF, rather than generic country risks. Risk mitigation measures are discussed in the risk section of the program or project document, focusing on the most relevant risks. SORT helps teams monitor risks consistently across all instruments and is updated throughout the life of an operation or country engagement.
The proposed ESF envisages a risk assessment approach where the Bank will classify all projects (including intermediated financing (FI) projects) into one of four classifications: High Risk, Substantial Risk, Moderate Risk or Low Risk. In determining the appropriate risk classification, the Bank will take into account relevant issues, such as the type, location, sensitivity, and scale of the project; the nature and magnitude of the potential environmental and social risks and impacts; and the capacity and commitment of the Borrower (including any other entity responsible for the implementation of the project) to manage the environmental and social risks and impacts in a manner consistent with the ESSs. Other areas of risk may also be relevant to the delivery of environmental and social mitigation measures and outcomes, depending on the specific project and the context in which it is being developed. These could include legal and institutional considerations; the nature of the mitigation and technology being proposed; governance structures and legislation; and considerations relating to stability, conflict or security.
The ongoing review and update of the Banks safeguard policies continues to provide opportunities that are not policy-related for OPCS and the relevant Global Practices to review and improve application, implementation, supervision, monitoring, reporting, and evaluation of activities under the existing safeguard policies.
7.3a) The World Bank should: Assign responsibility and budget for safeguards oversight and reporting to environmental and social units in each operational Regionin line with IFC practicein place of the delegation of safeguards processing and supervision to sector management units. Disagreed, no follow up
7.3b) Introduce a certification program to expand the pool of staff qualified to undertake social and environmental preparation and supervision while ensuring quality and consistency, and provide orientation training on environmental and social sustainability to all task team leaders. Agreed/ongoing
One of the IEG recommendations that has received a lot of traction.
7.3c) Develop and implement an action plan to ensure regular supervision of financial intermediary projects and investment projects that use social and environmental policy frameworks through third-party or community monitoring for higher-risk projects, and disclosure of monitoring and supervision reports.
The actions taken by the Bank (Africa/South Asia Review, training, webpage etc.) are noted. However, they do not address the IEG recommendation, namely: Develop and implement an action plan to ensure regular supervision of financial intermediary projects and investment projects that use social and environmental policy frameworks.
The Bank actions indicated are primarily focused on the preparation of quality Frameworks, which is important. However the recommendation focuses on the supervision of projects using Frameworks, which is not addressed and is of equal or greater importance.
Operational Course for Task Team Leaders Completed.
Three E-Learning Modules on Safeguards have been prepared cooperatively by OPCS, LEG and SDN, to supplement the face-to-face safeguards training program offered by QACU. They have become part of the Operational Core Curriculum (OCC) developed by OPCS, with Module 3 targeted at TTLs.
Accreditation Process / Environment Ongoing
ENV is implementing an Environmental Safeguards Accreditation process for environmental specialists involved in project preparation and supervision. The process includes the designation of suitable staff by their respective managers, a one week compulsory course, face-to-face peer review and operational mentoring in the field, leading to accreditation by the Sector Board. Environmental Accreditation material has been developed. A pilot training course was conducted with a core safeguards team on January 9-13, 2012 and 24 specialists fro, across the Bank were trained on May 14-18, 2012. Training courses and field mentoring will be done in all 6 regions in FY13 for field based staff and local consultants.
Accreditation Process / Social Ongoing
A Social Development Training and Accreditation program has been developed and began in June 2011. The program covers for basic competency areas including social safeguards. The program consists of 4 components: (a) e-learning; (b) face-to-face training; (c) mentoring; and (d) practical field experience. Under this program 56 staff from both headquarters and field has been trained to date. The next session is scheduled for February/March 2013.
Community of Practice. Both ENV and SDV have initiated the establishment of communities of practice for environmental and social specialists, respectively. The SDV community of practice has been active since 2009 and the ENV community of practice since 2011. World Bank Management reviewed the use of frameworks and made a decision to do a detailed examination of the performance of projects using environmental and social management frameworks (ESMFs) in the Africa and South Asia Regions. These reviews covered over 80 active projects across sectors and themes. A standard methodology was applied with extensive documentation that reviewed all aspects of preparation of the frameworks and implementation. Recommendations were provided on actions to improve the practical use of frameworks across the Bank, including the identification of good practice approaches. A guidance note on the use of Environmental and Social Management Frameworks (ESMFs) is being prepared by QACU, LEGEN and AFTSG,
QACU sponsored training on the use of safeguard frameworks in January 2012, using resource staff from QACU, LEGEN and ECA. There will be further sessions in February and April 2012. QACU is in the process this fiscal year of creating a new webpage called Frameworks on its anchor website that will contain Bank wide information in one central repository for the community of practitioners. This site will hold examples of good ESMF products, sample of good sections in operational manuals, ToRs for contracting the development of frameworks, samples of checklists, screening forms and other guidance and tools.
As stated in the Original Response, Bank Management does not agree and will not be held accountable in future Management Action Records for asking clients to implement third-party or community monitoring.
IEG notes that the Management is using the ongoing safeguards review and update process to improve the application, implementation, supervision, monitoring, reporting and evaluation of activities under the existing safeguard policies. It is also encouraging that the Management is considering ways to transform the approval culture to one that emphasizes implementation, quality and results. In this regard, IEG looks to specific actions and outcomes in the next Management Update.
IEG notes the significant progress made since the last Management Update in the certification program for expanding the pool of staff qualified to undertake social and environmental preparation and supervision, and to provide orientation training on environmental and social sustainability to all task team leaders. However, there still appear to be some unresolved issues relating to proposing staff for accreditation, on assigning accredited staff to projects of different safeguards categories, etc. Progress in addressing these matters is crucial for the accreditation process to be effective.
The creation of E-learning modules on Safeguards jointly by OPCS, LEG and SDN, and their inclusion in the Operational Core Curriculum (OCC) developed by OPCS is a positive development.
The creation and activities (meetings, joint sessions) of the communities of practice for environmental and social specialists is noted and IEG looks to information on their progress and impact in the next update.
In respect of supervision of financial intermediary (FI) projects, the Management update mostly recounts the actions mentioned in the previous update, relating to the Africa/South Asia Review, training events, and informational webpages. There is no new information to suggest that any steps have been taken to ensure regular supervision of financial intermediary projects and investment projects that use social and environmental policy frameworks, as was the thrust of the IEG recommendation.
Disagreed. Management continues to assess risk, including that related to environmental and social safeguards, with the ORAF process, which provides for an integrated evaluation of projects. This is complemented by regular review undertaken by QACU of regional lending programs, including projects under preparation and implementation, to assess potential environmental and social impacts and risks and to facilitate effective allocation of available human resources to undertake safeguards work. This includes examination of potential reputation risk and supports the ORAF process.
The review and update process provides an opportunity to undertake in parallel a number of complementary Management actions to improve the application, implementation, supervision, monitoring, reporting, and evaluation of activities under the existing safeguard policies. Some of these actions have already been indicated in the Management Action Record in response to the IEG evaluation, and are under implementation. Additional complementary procedural and guidance changes that need not involve policy changes are currently being identified, with a view to improving the quality of projects through both upstream preparation and downstream supervision. Management is also considering ways to transform the Bank's approval culture to one that emphasizes implementation, quality, and results.
Incentives for safeguards work and staffing are being addressed as part of the work related to environmental and social accreditation of staff (see below).
Please see below for more detailed information on ongoing work concerning projects that use environmental and social management frameworks. See also Item 5 for a discussion on the risk management framework that is under development to assist teams in their efforts to prioritize implementation of grievance mechanisms more broadly and to enhance quality assurance.
Agreed/Ongoing.
Operational course for Task Team Leaders Completed.
Three E-Learning Modules[1] on Safeguards have been prepared cooperatively by OPCS, LEG and SDN, to supplement the face-to-face safeguards training program offered by QACU. They have become part of the Operational Core Curriculum (OCC) developed by OPCS, with Module 3 targeted at TTLs.
Accreditation Process / Environment Ongoing
ENV is implementing an Environmental Accreditation process for environmental specialists involved in project preparation and supervision. The process will include the selection of suitable staff, a one week compulsory course, an E-Learning Module/test, face-to-face peer review and operational mentoring in the field, leading to accreditation by the Sector Board. Following the pilot session in January, which led to the accreditation of 18 specialists, three Environmental Accreditation training sessions have been completed:
- May 2012 at headquarters 24 specialists
- November 2012 in Lima, Peru 26 specialists
- December 2012 in Delhi, India 31 specialists
-February 2013 in Cape Town35 specialists
-February 2013 at headquarters 35 specialists
- April 2013 in Bangkok 35 specialists
Additional sessions are being planned during the next fiscal years both at headquarters and in the field.
Accreditation Process / Social Ongoing
A Training and Accreditation Program for Social Development (TAPSD) has been developed and consists of 4 components: (a) e-learning; (b) face-to-face training; (c) mentoring; and (d) practical field experience. The TAPSD has been offered twice to date, to 52 participants. Another session, is scheduled for later in February 2013 for an additional 30 participants.
Community of Practice.
Both ENV and SDV have initiated the establishment of communities of practice for environmental and social specialists, respectively, which hold regular meetings, including joint sessions.
Agreed/Ongoing. World Bank Management reviewed the use of frameworks and made a decision to do a detailed examination of the performance of projects using environmental and social management frameworks (ESMFs) in the Africa and South Asia Regions. These reviews covered over 80 active projects across sectors and themes. A standard methodology was applied with extensive documentation that reviewed all aspects of preparation of the frameworks and implementation. Recommendations were provided on actions to improve the practical use of frameworks across the Bank, including the identification of good practice approaches.
A guidance note on the use of Environmental and Social Management Frameworks (ESMFs) is being prepared by QACU, LEGEN and AFTEG.
QACU sponsored two training sessions on the use of safeguard frameworks in 2012, using resource staff from QACU, LEGEN and ECA. Fifty-seven staff participated in these sessions.
QACU has developed an intranet page called Frameworks http://go.worldbank.org/R42LO817I0 on its anchor website that contains Bank wide information in one central repository for the community of practitioners. This site holds examples of good ESMF products, sample of good sections in operational manuals, ToRs for contracting the development of frameworks, samples of checklists, screening forms and other guidance and tools.
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[1] The OPCS OCC Webpage
http://intranet.worldbank.org/WBSITE/INTRANET/UNITS/INTOPCS/0,,contentM…
The Description of the Safeguards Learning
http://intresources.worldbank.org/INTOPCS/Resources/380831-129441542363…
IEG rates the adoption of Recommendation #55 Sections 7.3 b and 7.3b as Medium and the Status Active.
IEG recognizes that a number of Management actions to improve the application, implementation, and supervision of safeguard related activities are being taken in parallel to the review and update process of the Bank's safeguard policies and that additional complementary procedural and guidance changes (that need not involve policy changes) are currently being identified, with a view to improving the quality of projects through both upstream preparation and downstream supervision. As demonstrated by the recent Internal Audit Department (IAD) review, and as pointed to in IEG's 2013 MAR response, there remain unresolved issues related to the assignment of accredited safeguard staff to projects of different safeguard categories, etc. Progress in addressing these matters is crucial for the accreditation process to be effective. IEG also notes that there is no new information provided on steps have been taken to ensure regular supervision of financial intermediary projects (apart from the policy changes) and investment projects that use social and environmental policy frameworks, as was the thrust of the IEG recommendation.
Disagreed. Management continues to assess risk, including that related to environmental and social safeguards. This was done previously with the ORAF process (which provides for an integrated evaluation of projects) and which is currently planned to be replaced with the new Framework for Management of Risk in Operations that the World Bank is proposing to launch in October 1, 2014. The proposed Framework and new Systematic Risk-rating tool (SORT) would address the recommendations of the Risk and Accountability Working Group, and the findings of the Internal Audit Department (IAD) Annual Report of 2012. The new Framework for Management of Risk in Operations will apply to all Bank-supported operations and Country Partnership Frameworks (CPFs); and rests on three pillars: (i) Systems and Tools; (ii) Structure and Organization; and (iii) Culture.
This is complemented by regular review of regional lending programs, including projects under preparation and implementation, to assess potential environmental and social impacts and risks and to facilitate effective allocation of available human resources to undertake safeguards work which OPSOR carries out frequently. This includes the examination of potential reputation risk and supports the ORAF - and going forward the SORT - process.
Moreover, the review and update process of the Bank's safeguard policies continues to provide an opportunity to undertake in parallel a number of complementary Management actions to improve the application, implementation, supervision, monitoring, reporting, and evaluation of activities under the existing safeguard policies as has been already indicated in the Management Action Record in response to the IEG evaluation, and are under implementation. Additional complementary procedural and guidance changes that need not involve policy changes are currently being identified, with a view to improving the quality of projects through both upstream preparation and downstream supervision. Management is also considering ways to transform the Bank's approval culture to one that emphasizes implementation, quality, and results.