A presentation on access to information policies at development banks by WRI's Sustainable Finance Team.

1. ACCESS TO
INFORMATION AT
DEVELOPMENT
BANKS
Gaia Larsen, Roland Widmer & Bradley Schliesmann Photo: flickr / Gerardo Pesantez / World Bank

2. INTRODUCTION
Transparency is vital for good governance and
effective, sustainable development. Access to
information is a key element of development
effectiveness. Information allows the public to
understand the actions of their government and the
financial institutions active in their country,
and helps people hold these actors accountable
for their actions.
As a result of public pressure to embrace transparency,
many development banks have developed policies to
allow public access to information about their
activities. These policies aim to clarify what
information is available to the public, how the public
can access that information, and what types of
information are to be kept from public access.

3. GLOBAL DEVELOPMENT BANKS
The following global development banks are included in this slide deck:
• World Bank (WB, composed of IBRD & IDA) – finances public actors globally.
• International Finance Corporation (IFC) – finances private actors investing in
developing countries.
• Multilateral Investment Guarantee Agency (MIGA) – provides political risk
insurance guarantees to private companies investing in developing countries.
Photo: flickr/International Rivers; flickr/Luke Mackin; flickr/ CGIAR

4. DOCUMENTS REVIEWED –
GLOBAL DEVELOPMENT BANKS
Instit. Policy Related Documents1
WB
• Policy on Disclosure and Access to
Information (2012)
• Disclosure and Access to Information
Handbook
IFC • Public Communications Policy (2011)
• ADB Disclosure Handbook
• Translation Framework
• Safeguard Policy Statement
MIGA • Public Information Policy (2014) • Environmental and Social Policy
1 These documents provide further details on how the ATI policy is to be implemented.

5. REGIONAL DEVELOPMENT BANKS
The following regional development banks are included in this slide deck:
• African Development Bank (AfDB) – supports public and private actors in Africa.
• Asian Development Bank (ADB) – supports public and private actors in Asia.
• European Bank for Reconstruction and Development (EBRD) – supports micro, small
and medium-sized enterprises in Europe, western Asia, and northern Africa.
• European Investment Bank (EIB) – invests primarily in the poorer European countries.
• Inter-American Development Bank Group (IDB) – supports governments and
companies in Latin America and the Caribbean.

6. DOCUMENTS REVIEWED –
REGIONAL DEVELOPMENT BANKS
Instit. Policy Related Documents
AfDB
• Policy on Disclosure and Access to
Information (2012)
• Disclosure and Access to Information
Handbook
ADB • Public Communications Policy (2011)
• ADB Disclosure Handbook
• Translation Framework
• Safeguard Policy Statement
EBRD • Public Information Policy (2014) • Environmental and Social Policy
EIB • EIB Transparency Policy (2010)
• Guidance Note for Promoters and
Partners on the EIB’s Transparency
Policy
• EIB Statement of Environmental & Social
Principles & Standards
IADB • Access to Information Policy (2010)
• Environment and Safeguards
• Compliance Policy

7. NATIONAL DEVELOPMENT BANKS
These national development banks that are included in this slide deck:
• Development Bank of Southern Africa (DBSA) – a South African bank which
supports primarily large infrastructure projects in southern Africa
• French Agency for Development (AFD) – public development finance institution
that fights poverty and fosters economic growth in low and middle income
countries and the French Overseas Provinces
• Overseas Private Investment Corporation (OPIC) – U.S. Government’s development
finance institution, which mobilizes private capital to support U.S. companies
investing in developing countries

8. DOCUMENTS REVIEWED –
NATIONAL DEVELOPMENT BANKS
Instit. Policy/Law Related Documents
AFD
• Transparency Policy (2007)
• French Law on Development Policy and
International Solidarity (2014)
• Annex to the Transparency Policy;
French Law 2014-773
• Interdepartmental Committee on
International Cooperation &
Development (2013): Summary of
Decision
DBSA
• DBSA Promotion of Access to
Information Act: A Guide to Access
Information (2012)
• DBSA Environmental and Social
Safeguard Standards (2014)
OPIC
• United States Freedom of Information
Act (FOIA)
• FOIA regulations, at 22 C.F.R. Part 706
• Open Government Plan
• Information Quality Guidelines
• Environmental and Social Policy
Statement (2010)
• FOIA FAQ

9. NATIONAL DEVELOPMENT BANKS
NOT REVIEWED
While some national development banks have developed access to information
policies (often in reaction to legal requirements associated with their home country),
other national banks still lack policies outlining the public’s right to gain access to
information about their activities. This includes some of the world’s largest
development banks, such as:
• Brazil’s National Development Bank (BNDES) and
• China Development Bank (CDB)
Due to the lack of policies at these institutions, we did not include them in this
analysis.

10. WHY
TRANSPARENCY?
Photo: flickr/FXP

11. STATED INTENT OF THE ATI POLICIES
The Access to Information (ATI) policies of the development banks aim to boost
institutional effectiveness in delivering development results. This appears to be
particularly true for the global and regional banks:
• The IFC “believes that transparency and accountability are fundamental to fulfilling
its development mandate.”
• The ADB policy aims to “[i]ncrease the development impact of ADB operations.”
• The IDB expects that transparency will “improve the quality of its operations.”

12. TRANSPARENCY, ACCOUNTABILITY
& LEGITIMACY
Development banks state that transparency can increase accountability:
• AfDB: “through greater transparency, stakeholders are able to monitor the
outcomes of Bank Group operations and therefore help assure that benefits reach
the intended beneficiaries.”
• World Bank: greater openness “not only assists in exposing potential wrongdoing
and corruption, but also enhances the possibility that problems will be identified
and addressed early on.”
They also state that transparency builds trust and legitimacy:
• ADB: an objective of the policy “is to enhance stakeholders’ trust in and ability to
engage with ADB.”
• EBRD: “believes that transparency and accountability are fundamental to…
strengthening public trust in the EBRD.”
• IFC: “when clients are committed to transparency and accountability they help
promote the long-term profitability of their investments.”

13. WHAT DO THE
POLICIES
INCLUDE?
Photo: flickr/Evgeni Sotov

14. PRESUMPTION IN FAVOR OF ACCESS
The ATI policies are based on certain fundamental principles. One such principle is to
maximize disclosure by making all information open and available to the public unless
it falls into one of the limited and clearly defined exceptions. This principle is known as
the “presumption in favor of access.”
Global Regional National
IFC MIGA WB AfDB ADB EBRD EIB IADB AFD DBSA OPIC
Does the policy have
a presumption in
favor of access?
Yes Yes Yes Yes Yes Yes Yes Yes No Yes1 Yes
1 South Africa’s Promotion of Access to Information Act provides a presumption in favor of access, which legally should apply to DBSA. The
DBSA policy does not specifically state this however.

15. PROACTIVE DISCLOSURE
One main way that the development banks give access to information is by providing
such information regularly on their website, or at information centers at their
headquarters and in-country offices without people having to ask for it first.
ATI policies tend to list at least
some of the information
that the banks must disclose
proactively to the public,
which allows people to access
that information without
having to first submit a request
to the institution.
Photo: flickr/Magnus Halsnes

16. EXAMPLES OF PROACTIVELY
DISCLOSED INFORMATION
Global Regional National
IFC MIGA WB AfDB ADB EBRD EIB IADB AFD DBSA OPIC
Board meeting
minutes
Yes Yes Yes Yes Yes Yes No Yes No No Yes
Board Committee
meeting minutes
Yes Yes Yes
Some-
times1 No No No Yes No No Yes
Project/Program
documents
Yes Yes Yes Yes Yes
Summ-
aries Yes Yes Yes No
Summ-
aries
Country Strategies Yes Yes Yes Yes Yes Yes Yes Yes Yes No No
Environmental & Social
Impact Assessments
Yes Yes Yes Yes Yes
Some-
times2 Yes Yes No No Yes
Information on how to
access information
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
1 When the committee makes a decision and a subsequent Board discussion is not expected.
2 Environmental and Social Impact Assessments are disclosed for Category A projects, summaries are disclosed for other typesof projects.

17. REQUESTS FOR INFORMATION
The development banks also provide
information upon request. All of the banks
have sections or divisions responsible for
overseeing implementation of their ATI
requirements, and requests for information
can usually be submitted to these bodies via
online forms, email, fax, regular mail, or in
person.
Photo: flickr/Meena Kadri

18. WHO IS RESPONSIBLE FOR
IMPLEMENTATION?
GLOBAL
IFC Public Affairs
MIGA Corporate Communications Unit
WB External and Corporate Relations; Archives Unit; Legal Department
REGIONAL
AfDB Communication and External Relations Department (CERD)
ADB Public Information & Disclosure Unit (InfoUnit)
EBRD Secretary General; Communications Department
EIB Communications Department
IDB Office of the Secretary – Access to Information Section
NATIONAL
AFD
Strategy, Partnership and Communication Directorate – Strategic Steering and
Accountability Division
DBSA Information Officer (CEO); Deputy Information Officer
OPIC Office of External Affairs; Office of the Chief Information Officer; FOIA Office

19. HOW LONG DO THE BANKS HAVE TO RESPOND?
GLOBAL
IFC Response in 30 days, unless additional time required due to scope of request.
MIGA “Endeavors” to respond within 30 days unless more time is required.
WB
Acknowledged within 5 working days, response within 20 working days. Additional time
may be needed.
REGIONAL
AfDB
Acknowledged within 5 working days, more comprehensive response within 20 working
days. More time may be needed in some special circumstances.
ADB
Acknowledged within 5 working days and notification as soon as a decision has been made
but no later than 20 working days.
EBRD
Acknowledged generally within 5 working days, not more than 10 working days. Normal
response within 20 working days, can be expanded to max 40 working days.
EIB Reply “without delay" no later than 15 working days.
IADB
Response within 30 calendar days; 45 calendar days for historic information. If more time is
required, the public information center will inform the requester.
NATIONAL
AFD Reply within 30 business days. If more time required, will contact requester.
DBSA Will inform the requestor of his decision within 30 days, may extend to max 30 days.
OPIC
The FOIA requires OPIC to respond within 20 working days of receipt. In unusual
circumstances, OPIC may require an extension of time or expedite process.

20. ARE TRANSLATIONS AVAILABLE?
GLOBAL
IFC
IFC will respond to requests in English, but if receives requests in other languages, will
try to respond in that language. Abides by WBG Translation Framework.
MIGA
MIGA will respond to request in English, but it receives requests in other languages, will
try to respond in that language. Abides by WBG Translation Framework.
WB
Official languages: Arabic, Chinese, English, French, Portuguese, Russian, and Spanish.
The Bank translates documents in accordance with the WBG Translation Framework.
REGIONAL
AfDB
Requests should be submitted to AfDB in English or French. However the Bank has the
discretion to accept requests made in another official language of a member country.
ADB
Will conduct translations based on Translation Framework. Criteria for undertaking
translation: audience literacy level, relevant languages, alternatives, time required, costs.
EBRD
Requests in Russian, German or French will be responded to in that language. May also
forward requests to Resident Offices for translation. Otherwise, response in English.
EIB
EIB's statutory documents are available in official EU languages, while others are
available in English, French and German. Other translation considered if wide interest.
IADB Should publish public versions of documents in all languages available.
NATIONAL
AFD Information is disseminated in its existing form in the language in which it was drafted.
DBSA Must provide a manual with certain information in at least 3 of South Africa’s languages.
OPIC [no mention in regulation]

21. HOW MUCH DO THE BANKS CHARGE?
GLOBAL
IFC
There may be a standard charge for hard-copy documents or for documents on electronic
discs or drives, other than a Summary of Investment Information, Summary of Advisory
Services Project Information, or an Environmental and Social Review Summary.
MIGA
There may be a standard charge for hard-copy documents or a CD-ROM, other than a
Summary of Proposed Guarantee or an Environmental and Social Review Summary.
WB
The Bank may charge reasonable fees for providing digital or hard copies, particularly for
requests that are complex or time consuming. The bank has not charged fees to date.
REGIONAL
AfDB [no mention in policy]
ADB [no mention in policy]
EBRD [no mention in policy]
EIB
An applicant may be charged a fee to cover for reasonable costs arising from making
available requested document(s).
IADB
The Access to Information Committee is responsible for establishing service fees and
standards. Currently no fees are charged.
NATIONAL
AFD No charge.
DBSA A requester must pay an access fee for reproduction, search and preparation of the record.
OPIC
Fees charged for cost of searching for, reviewing, duplicating, tabulating and compiling
information, based on intended use of the information. Can be waived in public interest.

22. WHAT TYPE OF INFORMATION DO THE
BANKS EXCLUDE FROM DISCLOSURE?
The ATI policies list information to be excluded from disclosure, either for a limited
period of time or forever. Exceptions to disclosure are vital to a successful ATI policy, in
order to ensure that truly sensitive information, which could cause harm if released,
remains closed to the public.
Good ATI policies recognize though
that these limitations should be clear
and limited, in order to ensure that
the policy supports transparency
rather than secrecy.
Photo: flickr/Tambako the jaguar

23. EXCLUDED INFORMATION
Can information be
withheld in relation to…
Global Regional National
IFC MIGA WB AfDB ADB EBRD EIB IADB AFD DBSA OPIC
Legal or investigative
matters?
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Deliberative policy making
processes?
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Financial information of
the institution?
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
National security and/or
the safety and security of
individuals & property?
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Personal privacy? Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No
Conservation/protection
of the environment?
Yes Yes Yes No No Yes No Yes No No No
May Information be
withheld by a member
country/third party?
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No

24. OVERRIDES
All of the global or regional banks also maintain a right to disclose information
that should otherwise be kept confidential in the face of an overriding public
interest or other form of harm.
Global Regional National
IFC MIGA WB AfDB ADB EBRD EIB IADB AFD DBSA OPIC
Can exemptions ever be
overridden for a public
interest or to otherwise
reduce harm?
Yes Yes Yes Yes Yes Yes Yes Yes No Yes
Some-
times1
Can information be kept
confidential in the public
interest/to reduce harm
even if it doesn’t fall in an
exception?
No No Yes No Yes No Yes Yes Yes No No
1 For example, implementation of the exception for personnel or medical files requires OPIC to balance the public interest of releasing the information.

25. APPEALING DECISIONS
TO WITHHOLD INFORMATION
Global Regional National
IFC MIGA WB AfDB ADB EBRD EIB IADB AFD DBSA OPIC
Does the policy or FOI law
require the bank to give a
reason for denying a request?
Yes Yes
not
expli-
citly1
Yes Yes Yes Yes Yes Yes Yes Yes
Is there a provision for
internal review4 of refusals?
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Is there a provision for
external review5 of refusals?
Yes Yes Yes Yes Yes No Yes Yes Yes No2 No3
May a complaint be brought to
an accountability mechanism
or national court?
Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes
1 In practice the World Bank does explain the reason for denying a request.
2 Although the person can complain to the Public Protector.
3 While OPIC does not have its own external appeals body, there is an option to seek mediation services from the Office of Government
Information Services at the National Archives and Records Administration. In addition, an appeal can be taken to the United States federal courts.
4 Internal appeals are reviewed by employees of the relevant institution.
5 External appeals are reviewed by people who are convened by the institution but not regular employees.

26. WHO IS IN CHARGE OF
REVIEWING APPEALS?
Who is in charge of an internal review? Who is in charge of external review?
IFC ATI Policy Advisor ATI Policy Panel
MIGA ATI Policy Advisor Access to Information Appeals Panel
WB Access to Information Committee Access to Information Appeals Board
AfDB Information Disclosure Committee Appeals Panel
ADB
Public Disclosure Advancement
Committee
Independent Appeals Panel
EBRD Secretary General n/a
EIB Secretary General EIB Compliance Officer
IADB ATI Committee External Panel
AFD Chief Executive Officer
Commission d’accès aux documents
administratifs
DBSA Information Officer n/a
OPIC Vice President & General Counsel n/a

27. STRUCTURES TO
ENSURE
IMPLEMENTATION
Photo: flickr/Daniel Go

28. IMPLEMENTATION
Photo: flickr/lecercle
Implementation of the development bank ATI policies is, of course, not automatic. The
development banks have undertaken steps to help ensure that their policies take
effect. In addition to the creation of divisions within the institutions focused on
information access and appeals processes, as mentioned above, this includes
dedicating funds toward implementation, training staff, monitoring implementation,
and reaching out to external stakeholders.

29. TRAINING
Photo: flickr/Jonathan
One challenge in implementing the ATI policies is
to ensure that everyone in the institutions is
aware of the policy requirements and their role in
implementing them. Several of the banks have
undertaken institution-wide training to help
ensure that everyone understands, and is on-
board with, changes in information management
at the institution. They have used different
incentives to encourage participation in these
trainings. The World Bank, for example, committed
to only allow email access to those employees
who had completed the access to information
training.
The national banks can sometimes receive training from a national body dedicated to
transparency. In South Africa, for example, the Human Rights Commission provides
free trainings and seminars for Deputy Information Officers at public and private
institutions such as the DBSA.

30. INFORMATION MANAGEMENT
Photo: flickr/Artform Canada
One of the main challenges associated with implementing
an ATI policy is ensuring that information is properly
catalogued, organized and archived. Several of the banks,
including the World Bank, ADB and OPIC have invested in
centralized information management systems to make it
easier for staff to catalogue and distribute information.
The banks have taken different approaches to dividing
responsibilities within the institution. The ADB, for example,
has designated “publishers” and “focal points” throughout
the bank to help support implementation if the ATI policy
and created an internal help desk to answer staff questions.
Some banks have started to provide data in formats that can
be read by computer, which renders the information useful
for a broader range of purposes.

31. MONITORING
Most of the reviewed development bank ATI policies or national freedom of
information (FOI) laws include provisions for monitoring implementation and
reporting results. Some banks (e.g. the IDB) provide specific monitoring indicators in
their policy.
Global Regional National
IFC MIGA WB AfDB ADB EBRD EIB IADB AFD DBSA OPIC
Does the policy require
monitoring of
implementation?
Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes
How often does the policy
require the institution to
report publically on
implementation?1
“ongoing
basis”
“ongoing
basis”
“periodi-
cally”
Yearly Yearly Yearly
Does
not
specify
Yearly Yearly Yearly
Yearly &
quarterly
1 Institutions may report more often than required by their policies. For example, the World Bank publishes annual reports, as well as monthly
updates on requests received and granted.

32. OUTREACH
A final but vital step in successful implementation of an ATI policy is ensuring that the
public is aware of the policy and how to take advantage of the access to information
that it provides. Some banks have started to conduct such outreach and training. The
World Bank, for example, has held outreach sessions for the members of civil society
during its annual meetings. In 2013, World Bank staff carried out outreach missions in
six country offices in the South Asia and East Asia and Pacific regions.
Photo: flickr/CGIAR/P. Casier;flickr/International Rivers

33. CONCLUSION –
MULTILATERAL DEVELOPMENT BANKS
Transparency can increase accountability, strengthen
trust, enhance legitimacy, and help promote the long-
term success of investments. Many development banks
have made progress in recent years to enhance their
operational effectiveness through greater
transparency. This includes, in particular, the World
Bank Group and regional development banks, which
have created relatively strong policies aimed at
improving public access to information. The greatest
challenge now for these institutions is to ensure
effective implementation of their policies to ensure
that transparency truly permeates their activities.

34. CONCLUSION –
NATIONAL DEVELOPMENT BANKS
Some national development banks have also created
policies to allow access to information about their
activities, although generally their policies provide less
access to information than those of their multilateral
and regional counterparts. National development bank
actions for transparency are often the result of national
freedom of information (or access to information) laws
requiring transparency at government institutions.
Of the national developments banks analyzed in this
paper, OPIC appears to engage most actively in ensuring
public access to information about its activities. On the
other side of the spectrum lie those national
development banks that have yet to create publically
available policies ensuring public access to information,
such as the Brazilian or Chinese development banks.

35. END
Photo: flickr / Gerardo Pesantez / World Bank