Cultivating Ethics and Values - World...

FY17 ANNUAL REPORT

Ethics & Business Conduct

Cultivating

Ethics and

Values

CONTENTS

Who We Are 1

Letter from the Vice President and Chief Ethics Officer 2

Outreach, Training, and Values 3

Ethics Advisory Services 6

Business Integrity Review 10

Looking Ahead 18

Contacting EBC 20

Who We AreThe World Bank Group’s twin goals are to eliminate extreme poverty by 2030 and to

boost shared prosperity for the bottom 40 percent of each developing country. For

the diverse workforce of the Bank Group, integrity, ethical behavior, and adherence to

corporate values are core to the success of these goals.

Every year, thousands of Bank Group staff interface with EBC for guidance in

ethics, help navigating Staff Rules, advice on the ethical dimensions of operations,

customized trainings—and also for concerns about potential misconduct.

EBC is an independent vice presidency within the Bank Group that reports directly to

the president.

The Ethics and Business Conduct Vice Presidency (EBC) promotes the development and application of the highest ethical standards by staff members in the performance of their duties.

independence, impartiality, and integrity

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LETTER FROM

VP and Chief Ethics OfficerThank you in advance for taking the time to read EBC’s Annual Report for fiscal year 2017. Our performance, our successes are measures of the culture and reputation of the World Bank Group, so your attention to this is very welcome.

I am extremely pleased to present this report, as it has been a pivotal, very busy year for EBC.

Key to this is our restructuring in response to recommendations from the external review we began at the end of last fiscal year. Through this, EBC created an Outreach, Training, and Values unit to focus on cultivating a proactive approach to ethics—emphasizing values, education, and prevention. A strong communications plan underpinned these efforts. This year the unit focused on soliciting input from across the Bank Group to feed into our new corporate values that will launch this fall.

We posted a senior EBC staff member to the field for the first time to increase our access to country offices. We also made more outreach and training visits to country offices this year. At a personal level, it was a great pleasure to meet many colleagues across the globe to learn about how their needs and circumstances relate to EBC’s work.

The restructuring also allowed us to review our delivery model, strengthen protocols, and reduce transaction costs. I assure you that EBC is stronger and nimbler because of these efforts.

However, there is much more to this year’s story. The ethics office of the Bank Group is only fully performing its role when we create more bridges with operations; here we have begun to make significant inroads. EBC has the knowledge to help identify conflicts of interest, dilemmas, consequences, and gaps in projects that have ethical and risk implications. We look forward to more ways to leverage this expertise.

In addition, this year EBC started to explore a more diverse repertoire of corrective mechanisms when asked to address issues that fall short of misconduct or are more appropriately resolved at a lower level—while continuing to conduct investigations when necessary. This is an important point, which leads me to the last achievement to highlight in this letter.

The most important measure of EBC’s effectiveness is whether staff come to us with their concerns. We were pleased to see a significant increase in the trust staff place in the Bank Group’s internal justice system, as measured by the general staff survey for 2017. We share pride in this improvement with our colleagues across the internal justice system.

I want to heartily thank Bank Group management for supporting EBC’s new direction. I also thank our strong partners in the Internal Justice Services, the Human Resources Development Vice Presidency, the Legal Vice Presidency, the Staff Association, and our informal Sounding Board. I offer my gratitude to the many colleagues who have responded to our outreach with enthusiasm and to those who have the confidence in our work to come to us for advice and action.

My very deep appreciation also goes to EBC staff who work behind the scenes with confidence, and professionalism to support the mission of the Bank Group and contribute to increasing respect and fairness in our workplace.

Sincerely,

Ousmane Diagana, Vice President and Chief Ethics Officer

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Outreach, Training, and ValuesThe Importance of a Values-based, Ethical Culture

Inspired by how Ford CEO Alan Mulally used values and behaviors to drive a cultural renewal at Ford Motor Company, Bank Group President Jim Yong Kim recognized the need to revisit the dated values statement for the World Bank and apply it across the Bank Group. In March of 2016, Bank Group senior management endorsed the Refreshing our Values initiative, recommending a bottom-up approach that would articulate and celebrate Bank Group core values, provide cues for behavior and decision making, and help motivate staff to deliver at full capacity.

EBC and the Human Resources Development Vice Presidency (HRDVP) have led the initiative and, in FY17, undertook extensive staff consultations—hearing from more than 400 staff from across the Bank Group in focus groups and more than 500 staff through an all-staff online engagement.

The new Bank Group core values will be launched in fall 2017.

After finishing the design and piloting phase, in FY17 EBC began rolling out a new workshop—Creating a Respectful and Harassment-free Workplace—in regions and Washington, DC. EBC staff delivered the workshop to staff in ten country offices and to one headquarters-based unit, with very positive feedback. EBC has grown the cadre of trainers prepared to deliver the workshop both from within the unit and among partners from the Internal Justice Services and HRDVP to increase the reach of the workshop. EBC also continued to provide Ethics Awareness training throughout the fiscal year.

A 2013 National Business Ethics Survey showed unequivocally that misconduct declines as ethics culture improves. The survey asked whether staff had witnessed misconduct in the previous 12 months. In organizations with a weak ethics culture, 88 percent of staff said they had. By contrast, 20 percent of staff reported seeing misconduct in organizations with a strong ethics culture. A 68-point difference tells its own story.

Employees Who Observed Misconduct in Previous 12 Months

MISCONDUCT DECLINES AS ETHICS CULTURE IMPROVES

© 2014, Ethics Research Center. Used with permission of the Ethics Research Center, www.ethics.org

88%

59%32%

20%

Weak |Weak-Leaning |

Strong-Leaning |Strong |

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In FY17, EBC reached 3,949 staff directly through outreach and training activities in Washington, DC and the following 30 country offices: Abidjan, Accra, Addis Ababa, Bangkok, Beirut, Bucharest, Cairo, Chennai, Chisinau, Colombo, Dhaka, Freetown, West Bank and Gaza, Hanoi, Kampala, Kathmandu, Kigali, Lomé, Luanda, Marrakesh, Mexico City, Monrovia, Nairobi, New Delhi, Port Moresby, Sana’a, Singapore, Sydney, Tbilisi, and Yaoundé.

TRAINING BY TOPIC (staff attendance)

1,553 Ethics Awareness

989 Creating Respectful and Harassment-free Workplace

400 Ethics at Work Learning Series

1,007 Refreshing our Values

LOCATIONS OF OUTREACH AND TRAINING ACTIVITIES IN FY17

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We all have a part to play. What’s yours?

Colleagues at the Ethics and Business Conduct Vice Presidency (EBC)

can provide advice and support.

ETHICSis not a spectator sport.

Learn more at http://ethics.worldbank.org

Communications

Strong communications underpinned EBC’s efforts to cultivate a values-based ethical culture this year. In FY17 EBC launched a well-read newsletter sent to all Bank Group staff, revamped our internal and external websites, touched colleagues with a high-visibility poster campaign (see graphic below), and continued our successful Ethics at Work series—holding three standing-room only events during the year. EBC also concentrated on regular, transparent communication of results through Bank-Group intranet kiosks, blogs from the Vice President and Chief Ethics Officer, and a town hall open to all staff that was livestreamed to country offices.

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Ethics Advisory ServicesIn FY17, EBC focused on boosting awareness among Bank Group staff of its role as a resource for advice on adherence to values, compliance with rules, assessment and management of conflict of interest risks, and—increasingly—support to policy and strategy.

As a result, FY17 was one of the busiest on record for Ethics Advisory Services. EBC responded to 846 requests for advice this year, compared to 777 requests in FY16. Despite the increase, EBC maintained its commitment to rapid response: 67 percent of queries were answered on the same day; 85 percent were answered within one day; 90 percent were answered within two days. On average, queries were answered within .8 of a day.

Approximately half the queries concerned either outside activities or future/former employment relationships.

EBC noted that—due to more widespread knowledge of our ability to address these issues—operational questions tended to be more complex than in the past. This led to active collaboration between Ethics Advisory Services and operational teams. Policy reforms that took place this fiscal year, such as the development of guidelines on operational conflicts of interest, also have allowed EBC to deepen collaboration, share knowledge, and make the rules friendlier to operations.

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TABLE 1. CONFLICT OF INTEREST CONSULTATIONS BY CATEGORY

FY17 FY16 FY17 FY16

Outside activities 311 284 37% 37%

Future or former employment 103 112 12% 14%

Close relatives /relationships 112 112 13% 14%

Vendor procurement 60 50 7% 6%

External service 48 48 6% 6%

Gifts, medals, honors 47 42 6% 5%

Personal financial interests 17 20 2% 3%

Public statements & disclosures 40 32 5% 4%

Operational 20 29 2% 4%

Other 88 48 10% 6%

846 777 100% 100%

CHART 1.ETHICS ADVISORY SERVICES CONSULTATIONS BY SOURCE

CHART 2.ETHICS ADVISORY SERVICES CONSULTATIONS BY GRADE LEVEL

IBRD64275%

GH+23528%

IFC16520%

GE to GG44352%

GEF7

1%

UA and UC799%

Others182%

Non-classified182%

MIGA142%

GA to GD718%

52percent of queries came from regular staff or staff under open-ended contracts

36percent were from term staff

9percent of queries came from short-term consultants

3percent came from others (for example, retirees, future hires, and relatives of staff members)

QUERIES RECEIVED IN FY17:

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Declaration of Interests Program

EBC oversees two Bank Group Declaration of Interest (DOI) programs, which are designed to mitigate real or perceived conflict of interest risks.

The Senior Management Team and Vice Presidents DOI Program requires the 40 most senior individuals in the organization, including the Bank Group President, to complete a declaration that is summarized and publicly posted on the internet. All new vice presidents receive individual briefings at the start of their appointment on compliance with the conflict of interest requirements of the Bank Group and senior management regularly consult EBC for guidance on conflicts of interest concerns.

The Staff DOI Program requires manager-level staff members, as well as designated staff in other sensitive roles, to complete a confidential DOI that is reviewed by EBC and external consultants to identify possible conflict of interest risks. (Members of the Bank Group Board are also subject to financial disclosure in a program that is run independently by the Corporate Secretariat.)

Of 2,352 declarations received in the FY16 DOI staff program, 93 percent were closed after an initial review. The remainder were referred by the external contractor in the first part of FY17 to EBC for further research. In approximately one-third of these cases, EBC determined that no further action was necessary. In 56 cases, EBC contacted the staff member to request more information and closed the declaration review with no further action needed.

In 34 cases, EBC closed its review upon providing guidance to staff—for example, alerting them to potential conflicts of interest that could arise in the event of changes to their work program relevant to their financial holdings. In the remaining cases, EBC implemented additional remedies, including directing staff to disclose particular assets to their manager (10 cases), requiring staff to recuse themselves from working on certain projects or deals (eight cases), and requiring staff to seek the approval of either their manager or the Outside Interests Committee in order to continue an outside activity or employment (four cases). This year, in no case was a staff member required to obtain EBC approval prior to purchasing or selling an asset or to divest. This reflects the generally high awareness of management-level staff concerning the Bank Group requirements about financial assets and outside positions.

In FY17, all 2,393 staff who were requested to file a Declaration of Interest in March 2017 complied with this obligation.

In the last week of June 2017, EBC requested 37 additional filers to complete a Declaration of Interest form. This supplementary program, rendered necessary by the discovery of a computer bug, was completed at the end of July 2017.

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Outside Interests Committee

The Staff Rules address staff members’ ability to participate in outside employment. While some activities do not require approval, others do. For certain staff grade levels, requests to engage in certain activities are considered by the Outside Interests Committee (OIC). The OIC comprises representatives from throughout the Bank Group and considers staff members’ requests to provide services to a for-profit entity or initiative, paid services to a non-profit entity, unpaid services to a non-profit entity that has a business relationship with the Bank Group, or services to a government.

In FY17, the OIC considered five requests and all were approved. They included a general approval for U.S. citizen and permanent resident staff members to work at voting stations during the U.S. presidential elections in November and an approval to allow new staff to complete professional assignments with no relation to the Bank Group activities. The OIC also approved the principle that staff can generally accept an honorary doctorate subject to a review by EBC to ensure that no conflict of interest arises; only cases involving conflicts of interest would be referred to the OIC for review.

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Business Integrity ReviewRegrettably, every organization faces staff who fail to uphold high standards of behavior. As part of our mandate, EBC diagnoses and manages incidents when staff bring forward concerns about potential misconduct, including workplace-related grievances, travel and benefits fraud, and staff noncompliance with personal legal obligations. This year 36 percent of cases were resolved, advised, or referred to other resolution mechanisms. This underlines EBC’s resolve to increasingly address allegations of inappropriate behavior that may not amount to misconduct through consultation, advice, and performance management—empowering managers and staff to make decisions within an ethical framework that translates into accountability and ownership.

When this approach is not possible or appropriate, EBC investigates possible misconduct with commitment to the principles of proper due process and concern for victims. EBC’s investigative process entails the receipt of an allegation, an assessment to determine whether it falls within EBC’s mandate, a preliminary inquiry to determine if there is sufficient basis for undertaking an investigation, the investigation (if appropriate), and case documentation and closure.

This year, 21 cases resulted in a formal investigation. If EBC finds sufficient evidence to substantiate allegations, and other resolution mechanisms are not available within the remit of EBC’s mandate, we submit a report to the Vice President of Human Resources Development, who imposes disciplinary sanctions if he determines misconduct has occurred.

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66percent of reporters were regular staff

6percent were consultants

28percent were non-Bank Group staff or anonymous reporters

52percent of reporters were from Part 1 countries

30percent were from Part 2 countries

18percent were non-Bank Group staff or anonymous reporters

28percent of cases were from Country Offices

57percent were from Washington, DC (15 percent were anonymous sources or external to the Bank Group)

15percent of investigation subjects were grade level GD and below

67percent of subjects were grade level GE and above

16percent of subjects’ grades were unknown (for example, subject was non-Bank Group staff, identity was unknown by the reporter, or staff member was seeking advice)

46percent of reporters were women

32percent were men (22 percent unknown)

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TABLE 2: CASELOAD FY15-FY17 BY CATEGORY

FY15 297 FY16 230 FY17 228

Non-Compliance with Staff Rules 64



Harassment 88 Harassment 51 Harassment 61

Abuse of Authority 48 Abuse of Authority 26 Abuse of Authority 31

Misuse of Bank Resources 36



Personal Legal Obligations 14



G-5 Domestic Issues 15 G-5 Domestic Issues 15 G-5 Domestic Issues 8

Retaliation 15 Retaliation 11 Retaliation 11

Sexual Harassment 7 Sexual Harassment 10 Sexual Harassment 11

Discrimination 10 Discrimination 8 Discrimination 7

Investigative processing time has been decreasing since FY15. The increase in investigative staff coupled with improved internal procedures and revised performance metrics has resulted in a shortening of EBC’s average time for investigations by 50 days in FY17. Similarly, the average time for a preliminary inquiry—that is, when EBC determines whether there is sufficient basis to undertake an investigation—has decreased by 29 days in FY17.

TABLE 3:FY17 CASES SUBMITTED BY EBC TO HRDVP

Location Category of Misconduct HRDVP Decision Subject’s Grade Level

HQ G-5 domestic issues Comply with HR Operations and provide evidence of full compliance

GF

CO Hostile work environment (harassment)

Pending GD

CO Misuse of Bank Group resources Termination, bar to rehire, restriction of access to Bank Group buildings

GB

CO Misuse of Bank Group resources Written censure in file for 1 year, withholding of future pay increases for 2-year period

GC

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Location Category of Misconduct HRDVP Decision Subject’s Grade Level

CO Misuse of Bank Group resources Termination, bar to rehire, restriction of access to Bank Group buildings, written censure in file indefinitely

GA

CO Misuse of Bank Group resources (benefits)

Termination, bar to rehire, full restitution to WBG medical provider, written censure in file indefinitely

GB

HQ Misuse of Bank Group resources Pending GE

CO Non-compliance with Staff Rules (conflict of interest)

Written censure in file for 3 years, no pay increases for 3 years

GA

CO Non-compliance with Staff Rules (reckless performance of duties)

Termination, bar to rehire for 5 years, restriction of access WBG buildings for 5 years, letter of misconduct to remain on file for 5 years

consultant


Termination and bar to rehire consultant


Demotion to level GD and ineligibility for promotion for 3 years

GE

CO Reckless performance of duties Pending GH

CO Non-compliance with Staff Rules (intentional misrepresentation of facts to be relied upon)

Demotion to level GC and ineligibility for promotion for 3 years

GD

CO Non-compliance with Staff Rules (theft)

Termination, bar to rehire, restriction of access to Bank Group buildings, written censure in file indefinitely

GA

HQ Hostile work environment (sexual harassment)

No finding of misconduct by HR GH


No finding of misconduct by HR GH


Written censure in file for 3 years GG

CO Non-compliance with Staff Rules (theft)

Decision pending GC

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Eighteen cases were referred to the Vice President of Human Resources Development in FY17 for a disciplinary determination based on EBC’s fact-finding.1 Below are synopses of some of the closed cases:

> Non-Compliance with Staff Rules (theft): A staff member stole a personal laptop computer belonging to another staff member from Bank Group premises. His employment was terminated with permanent bar to rehire. He was also barred from Bank Group premises and a written censure was placed indefinitely in his personnel file.

> Misuse of Bank Group resources (medical insurance fraud): A staff member submitted fraudulent invoices to the Bank Group medical insurance provider and received reimbursement. He was terminated, barred from rehire, required to return the amount to the Bank Group medical provider, and a written censure was placed indefinitely in his personnel file.

> Abuse of Authority/Abuse of Bank Group funds relating to petty cash or property: A staff member coerced certain country office staff into colluding in the misrepresentation of repairs to Bank Group vehicles, falsifying petty cash requests for vehicle supplies, and working with auto repair garages to inflate the costs of vehicle repairs and supplies. The staff member was terminated, permanently barred from future employment with the Bank Group, and barred from Bank Group premises.

Another staff member who was involved in this matter was also found to have committed misconduct resulting in a written censure in her personnel file and no salary increase for two years.

1 A total of 18 cases were submitted to the Vice President of Development Human Resources during FY17, which included 11

cases that were initiated in the prior fiscal year. Another staff member entered into a Memorandum of Understanding.

Business Integrity Review

CONTINUED

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CASE STUDY

How We Learn from Investigations: Preventing FraudWe all can easily agree that preventing fraud is important. At EBC, we feel this even more acutely given that we have this responsibility within a development institution, where we have a special responsibility to protect funds that are destined to eliminate extreme poverty and boost shared prosperity.

This year, EBC dealt with fraud cases whose lessons are applicable across the Bank Group. One case involved the management of unused travel advances and repeated, fraudulent SAP entries in a country office. There, we saw that inadequate segregation of duties increased the risk of fraud. We recognized this as a very important finding, as in resource-constrained environments colleagues are often asked to multi-task. EBC shared these lessons with our partners in Bank Group oversight units, and—as a result—at least one similar case of fraud was discovered.

EBC’s cross-unit collaboration led to a financial audit review of the monthly bank reconciliations of selected country offices. Manual entries in SAP were compared with balances in bank statements to ensure they were fully reconciled. The review focused on country offices where it was identified that only one accountant handled both cash and accounting systems.

In one office, the review uncovered bank charge entries in SAP during the previous 12 months, amounting to nearly $10,000, that were not reflected in bank statements nor receipts. This was a red flag pointing to the possibility of false accounting entries and misappropriation of unused travel advances.

EBC’s ensuing investigation found that, as in the previously investigated case, one staff member in that office was responsible for handling both cash

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While of course it is unfortunate to find misconduct, EBC is taking a holistic approach to look for systemic issues and communicate them to relevant parts of the Bank Group.

and accounting processes in SAP. In both cases, the line supervisor was located in another country and the supervisor’s visits to the country office were scheduled ahead of time, which allowed for the fabrication or manipulation of information. When we approached several staff members who had received cash advances, they all confirmed that they had returned any unused funds from their travel advances—but none had requested or been offered a receipt for handing over the cash.

The lessons from these two cases are quite simple: EBC recommends that country managers avoid the use of cash wherever possible and maintain adequate oversight over all accounting functions. It is also critical to ensure a separation of duties between staff members handling cash and those entering transactions in SAP. Country office accountants should retain all requisite bank transaction records. Finally, where the use of cash cannot be avoided, all staff members should use receipts to record cash transfers. If these measures are adopted, we hope to fend-off any further potential copycat instances across the Bank Group.

This year, EBC also investigated a case that found a staff member misused Bank Group Resources by creating fictitious group travel requests for seminars and workshops, diverting travel advance SAP invoices through accounts payable, receiving advances through a private bank account, and creating fictitious statements of expenses without supporting documents. In this way, the staff member was able to misappropriate $234,000. While his contract ended in the course of the investigation, HRDVP sanctioned the staff member with a bar from re-hire and restrictions in access to Bank Group premises.

Here too, EBC was able to identify control failures in SAP that we shared with relevant units.

While of course it is unfortunate to find misconduct, EBC is taking a holistic approach to look for systemic issues and communicate them to relevant parts of the Bank Group. This is important in order to resolve matters at the most appropriate level, while still safeguarding the Bank Group’s ethical norms.

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Looking AheadEBC’s year has been active, as we consolidated our reforms and completed our restructuring.

EBC vision for the future is even more dynamic, as we endeavor to further strengthen the values-based ethical culture of Bank Group staff, delve deeper into operations where we can identify ethical concerns and conflicts of interest, and bring external awareness to emerging and sticky ethical issues in global development.

Specifically, EBC will look to develop more partnerships like the one we forged in FY17 with the Global Environmental Facility (GEF), where we engaged with staff and supported the Secretariat to create an Ethics Committee of the GEF Council. Taking this further, we hope that EBC is recognized as a resource to help Bank Group clients set up effective and modern ethics frameworks and offices.

In terms of our treatment of misconduct allegations, we will move from monitoring and reviewing cases to actively managing them with an eye toward even more effective resolution of conflict and increasing support to victims.

Annual reports tend to give data within context—an acceptable first-level analysis. Nevertheless, in the coming year we will pay more attention to underlying trends and red flags. Are there misconduct categories that appear underreported or under-adjudicated compared to other organizations? What are the regional discrepancies in requests for ethics advice and reporting of alleged misconduct? Do fewer reports from a unit or country office represent a positive indicator or rather indicate an ethical

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EBC vision for the future is even more dynamic, as we endeavor to further strengthen the values-based ethical culture of Bank Group staff, delve deeper into operations where we can identify ethical concerns and conflicts of interest, and bring external awareness to emerging and sticky ethical issues in global development.

“black box”? Do withdrawn complaints signal fear of retaliation? Moving forward, we will conduct root cause analysis on several issues and continue to look toward more systemic approaches.

Certainly, we’re looking forward to launching our new core values across the Bank Group in FY18. The challenge that we willingly embrace will be to keep the momentum going year-on-year. The Bank Group is inherently a values-based organization and they must be cultivated with care—and vigor.

Indeed, the world—and the Bank Group—is changing rapidly and EBC expects to keep up. We recognize that to be effective, staff need to focus on their clients and partners, not on grappling with bureaucracy or inefficient processes. EBC’s new approach is in line with agile methodology and the Bank Group’s strategic direction as outlined in the Forward Look. Our review of protocols, simplification of Staff Rules, and collaboration across units to achieve better results is a continuous mandate that will last through FY18 and beyond.

At a broader level, the strategic frameworks that currently guide the Bank Group’s direction—including maximizing financing for development by leveraging the private sector and optimizing the use of scarce public resources—imply tremendous culture change for their success. Much of this culture change involves a high level of ethical decision-making: for example, do we continue this project to maintain the status quo, or re-think and re-direct it, for the greater development good?

EBC is prepared to support the Bank Group fully in this sea-change.

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Contacting EBC Staff are encouraged to report alleged staff misconduct either to their managers or to EBC. Managers have an obligation to report such allegations to EBC.

EBC affords due process to all individuals involved in an integrity review—including those reporting alleged misconduct, witnesses, and subject staff members. Information about an integrity review and the identity of staff involved are disclosed only to individuals who have a legitimate need to know, consistent with Staff Rules. Staff have the option of reporting misconduct anonymously. However, no finding of misconduct can be made based on anonymous allegations unless the allegation of misconduct is independently corroborated.

Retaliation or threat of retaliation by a staff member against any person who reports suspected misconduct, or who cooperates or provides information in connection with an integrity review, is prohibited. Retaliation or threat of retaliation constitutes misconduct in and of itself and may be investigated as such by EBC.

Staff with questions relating to potential conflicts of interest are encouraged to contact EBC early, so that any concerns can be promptly addressed and effectively managed. Conflict of interest advice will be kept confidential between the advisory team and the staff member, but may be shared with others who have a legitimate need to know. For example, information that has been shared with EBC’s ethics advisory staff may be shared with EBC investigators if there is reason to believe that misconduct may have occurred.

TEL: 202-473-0279

FAX: 202-522-3093

EMAIL: [email protected]

ETHICS HELPLINE: 1-800-261-7497

(24 hours, 7 days a week; multiple languages)

INTRANET: http://ethics.worldbank.org

INTERNET: http://www. worldbank.org/ethics

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