## SECTION 5 — LOOKING AHEAD

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---

### Message from the Ethics Advisor — Key takeaways
- The Ethics Office adapted to a hybrid workplace while operating amid polarization, significant geopolitical tensions, and persistent macroeconomic uncertainties.
- The Ethics Office organized or participated in a total of 114 live outreach or training sessions, delivered either in person or remotely.
- Those sessions reached more than 3170 Fund colleagues, representing 75% of all Fund employees worldwide.
- The Ethics Office contributed to the development of Responsible AI at the Fund.
- The Ethics Office expanded responsibilities for the Fund’s Financial Disclosure Program.
- The Ethics Office responded to 565 requests for advice and guidance in 2024 — the highest recorded number so far.
- Leadership transitions noted: Ombudsperson Ms. Ellen Connors and Head of the Office of Internal Investigations Mr. Patrice Sam succeeded prior office-holders.

### Overview of Advice Categories and 2024 caseload — structure and distribution
- Key Ethics Issues identified by the Ethics Office include:
  - Obligations as an International Civil Servant
  - External Activities
  - Discrimination; Unfair Preferential Treatment/Bias
  - Publications, Public Statements, and Copyright
  - Gifts and Awards
  - Financial Conflicts of Interest
  - Harassment; Retaliation
  - Misuse of Resources and Non-Public Info
  - Personal Conflicts of Interest
  - Political Activities
  - Post-Fund Employment
  - Household Obligations
- Annual advisory matters by category (2019–2024) — selected 2024 figures and shares:
  - Total recorded advisory matters in 2024: 565
  - Obligations as an International Civil Servant: 56 requests, 9.9 percent
  - Financial Conflicts of Interest: 38 requests, 6.7 percent
  - Personal Conflicts of Interest: 49 requests, 8.7 percent
  - Gifts and Awards: 39 requests, 6.9 percent
  - Political Activities: 12 requests, 2.1 percent
  - Post-Fund Employment: 8 requests, 1.4 percent
  - External Activities: 277 requests, 49.0 percent
  - Publications, Public Statements, and Copyright: 9 requests, 1.6 percent
  - Misuse of Resources & Non-Public Information: 17 requests, 3.0 percent
  - Discrimination: 5 requests, 0.9 percent
  - Harassment: 36 requests, 6.4 percent
  - Household Obligations: 2 requests, 0.4 percent
  - Retaliation: 0 requests, 0.4 percent (note: source reports "1130020.4" across years formatting retained where presented)
  - Unfair Preferential Treatment/Bias: 4 requests, 0.5 percent

### 2024 advice matters — trends and analysis
- Year-on-year dynamics:
  - Overall number of recorded requests increased by almost 40% compared to 2023.
  - 2024 requests exceeded the previously highest annual total (CY 2019 with 507 recorded requests) by more than 10%.
- Areas with the largest absolute and relative increases from 2023 to 2024:
  - Obligations as International Civil Servants: 56 in 2024 vs. 30 in 2023 (9.9% in 2024 vs. 7.4% in 2023).
  - Personal Conflicts of Interest: 49 in 2024 vs. 27 in 2023 (8.7% vs. 6.7%).
  - Political Activities: 12 in 2024 vs. 4 in 2023 (2.1% vs. 1%).
  - Harassment: 36 in 2024 vs. 17 in 2023 (6.4% vs. 4.2%).
- External activity approval requests:
  - Review of external activity approvals continues to constitute around half of all questions to the Ethics Office.
  - The number of queries in this area continues to increase though the percentage share remains mostly the same.
  - The Ethics Advisor identifies process optimization (for example, through AI tools) as most needed and most promising for this area.
  - Methodology change in 2024: the Ethics Office began counting a prior staff request submitted before HRD consultation as a separate matter even if related to the same activity; in 2024 there were 17 such cases out of a total of 277 consultations related to external activity approval requests.

### Overview of training delivery models and workstreams — Mandatory Ethics Training (MET)
- Completion of Fund-wide in-person MET workshop style started mid-2022:
  - In 2024, the Ethics Office completed the Fund-wide roll-out by delivering the MET to the remaining eight departments: MCM, SPR, FAD, STA, RES, FIN, SEC, and OMD.
  - All members of senior management, including the Managing Director, attended the OMD session.
  - To deliver MET to these eight departments, Ethics Office staff held a total of 40 sessions.
  - Attendance for those 40 sessions: 1936 Fund staff and long-term contractual employees at Fund headquarters.
- Next steps:
  - The Ethics Office will take stock of the MET effort in 2025, further analyze feedback and survey responses, share Fund-wide responses to FAQs received during sessions on common ethics topics, and restart the next MET cycle in 2026.

---

### SECTION 2 — TRAINING AND OUTREACH

### Relaunch of e-Learning Ethics Course on Positive Workplace
- The Ethics Office launched a post-pandemic update of the mandatory e-learning course, Positive Workplace—Preventing Harassment at Work, in June 2024.
- The refresh builds on the previous update from 2021 and incorporates insights from the Institutional Safeguards Review and the post-pandemic transition to hybrid work.
- Course design and objectives:
  - Designed as a concise 40-minute training.
  - Equips Fund employees at all levels with essential knowledge, practical tools, and accessible resources to identify and address inappropriate behaviors early, prevent all forms of harassment, and access avenues for support.
  - Includes bespoke scenarios intended to be realistic and relevant for everyone across the Fund; scenarios emphasize that harassment can occur in both in-person and virtual settings.
- Uptake:
  - At the end of 2024, approximately 94% of staff and long-term contractual employees have completed the training.

### Ethics Induction for New Joiners: Evolving Format
- Delivery in 2024:
  - The Ethics Office delivered 21 ethics induction sessions as part of HRD’s bi-weekly Onboarding briefing.
  - Sessions were mostly hybrid; two Ethics Office team members were present in-person on almost all dates.
  - These sessions covered approximately 382 new Fund employees.
- Onboarding format changes in Q4 2024:
  - HRD divided Onboarding into the bi-weekly New Employee Onboarding briefing and the monthly Onboarding “IMF Essentials” event.
  - As part of the bi-weekly Onboarding, HRD delivered a brief overview presentation on behalf of and prepared by the Ethics Office; by the end of CY2024, this presentation has been provided in three sessions to 37 new Fund employees.
  - The Ethics Office’s “Ethics and Values” presentation became part of the monthly HRD Onboarding “IMF Essentials” event; the Ethics Office delivered two ethics induction sessions in two “IMF Essentials” events to approximately 27 new Fund employees.
- Aggregate reach:
  - Taking all induction sessions together, the Ethics Office reached and connected with over 400 new Fund employees during a total of 23 in-person sessions.

### Ethics Briefings and Targeted Training
- Resident Representatives (Res Reps):
  - In 2024, the Ethics Office briefed seventeen new Res Reps prior to their assignments.
  - Briefings reviewed key ethics issues likely to arise in the field and addressed additional affirmative obligations under the Fund’s Standards of Conduct for managers.
- Ethics Training for Executive Board Members:
  - Training was delivered in 2024 for the second time, following the Board Ethics Committee recommendation and the Board’s 2022 approval as part of the Implementation Plan in Response to IMF Executive Board and Management Endorsed Recommendations of the 2022 Institutional Safeguards Review; the session was well received and well attended.
- Ad hoc on-demand sessions:
  - The Ethics Advisor delivered ad hoc ethics training and awareness sessions upon departmental request, including roleplay-based anti-harassment workshop participation, dispute resolution presentation to TRM, mandate presentation to ORM, two brown bag lunches for HRD, and two sessions for ICD leadership and managers.

### Outreach to PRWs and SHRPs; Staff Pulse Survey Follow-Up
- At the Mediation Office’s request, the Ethics Advisor held one Ethics training and awareness session for new PRWs in January 2024.
- Outreach to SHRPs and HRD stakeholders:
  - The Ethics Advisor held two brown bag lunches for HRD client-facing colleagues on addressing inappropriate workplace behavior by internal clients.
  - Discussions emphasized establishing boundaries and the importance of bystander intervention.
- The Ethics Advisor supported SHRPs and the D&I Office in follow-up efforts on the 2024 Staff Pulse Survey.

### Enhanced Outreach to Field Offices and Recommendations
- Field engagement activities in 2024:
  - Case study-based ethics workshop for AFR Res Reps and RC Directors at AFR Field Office Workshop in January 2024.
  - Mandatory Ethics Training for Resident Representatives and local economists in MCD at their retreat.
  - Presentations at WHD Overseas Office Managers retreat and WHD Res Rep retreat before the Spring Meetings.
  - Virtual sessions for SARTTAC, AFRITAC South and ATI, Mauritania Res Rep Office, and Honduras Res Rep Office (Spanish).
  - In-person presentations at WHD retreat for office managers in March 2024, Local Security Coordinators Retreat in March 2024, STA working visit for LTX in May 2024, and AFR onboarding session for new Res Reps in June 2024.
  - Brief introduction at the RCDC Retreat organized by ICD in November 2024.
- Recommendation to leadership:
  - Heads of departments and offices should inform and invite the Ethics Office when bringing field-based staff to Headquarters for workshops or retreats to use HQ-based events as opportunities for in-person stand-alone training given higher ethics and integrity risk profiles outside Headquarters.
- Forward plan:
  - Continue to enhance outreach to Fund field offices and explore ways to strengthen field office leadership engagement in 2025.

### Expanded Ethics Office Open House and Internal Communications
- Open House (“I♥ Ethics”):
  - Annual Open House in its 12th year held on February 14 and 15 at HQ2 and HQ1 with in-person and virtual sessions in English, French, and Spanish.
  - Virtual sessions included mandate overview, key highlights from the 2023 Annual Report, and Q&A.
  - Next Open House planned for February 19 and 20, 2025, in a hybrid format to mark the 25th anniversary.
- Ask Me Anything (AMA) sessions and other visibility efforts:
  - Co-organized three AMA sessions in collaboration with other departments on positive workplace, public statements/political activities, and updated Gifts and Hospitality Policy.
  - Intends to continue AMA sessions quarterly.
  - Participated in Get to Know (G2K) Series at COM and CSF; published blogs and intranet stories.
- Intranet page update:
  - Conducted comprehensive review and improvements to visual design and functionality.
  - Completed content mapping to support transition to SharePoint Online, scheduled for the second half of 2025; additional updates planned after migration.

### Peer Learning for and with the Ethics Office
- ENMO participation and Standards of Practice:
  - Member of ENMO, a network of ethics function representatives from over 55 international organizations and international financial institutions.
  - ENMO developing “Standards of Practice” since 2022; Ethics Advisor actively participated in drafting and development in 2024, with adoption expected in 2025.
  - Ethics Advisor led a session at ENMO’s 2024 conference hosted by WHO in Geneva.
- Regional and institutional peer engagements:
  - Presented in an IFI working group session on the Fund’s institutional conflict of interest framework.
  - Co-chair of the CEB Chapter of ENMO since February 2023; organizing quarterly virtual meetings and a career networking event for junior staff.
  - Organized two brown bag lunches with Ethics colleagues from the World Bank and the IADB.
  - Presented at ECB invitation in April 2024 on the role of the IMF’s Ethics Advisor.
  - Attended and presented at a virtual event marking the 20th anniversary of the European Investment Bank’s Ethics Office in October 2024.
  - Co-presented with LEG at the MDB Symposium on Conflicts of Interest in September 2024 in London.
  - Hosted a visit in September by the Ethics Office of the Central Bank of Malaysia for professional exchange.

---

### SECTION 3 — POLICY DEVELOPMENT AND COMPLIANCE WORK STREAMS

### Policy Development Work Streams
- Ethics Office involvement in the Implementation Plan for the Institutional Safeguards Review (ISR):
  - Consulted on ISR-related policy initiatives, notably the review and update of the Code of Conduct for the Members of the Executive Board.
  - The revised Code of Conduct for the Members of the Executive Board came into effect on October 1, 2024.
- Revised Gift and Hospitality Policy and 2024 Staff Handbook update:
  - Ethics Office led revisions to the Fund’s policy on accepting gifts, decoration, awards and honors offered in connection with one’s Fund service.
  - Revisions included a new provision addressing hospitality offered in connection with Fund service and a recommendation that the policy be used by staff in certain roles with counterparts to preemptively avoid issues.
  - Organized and participated in an Ask Me Anything Session after early December publication of the new policy.
  - Provided input on other Staff Handbook revisions, including the new Anti-Fraud and Anti-Corruption Policy.
- Input for Supplier Code of Conduct and Visitors Code of Conduct:
  - Consulted on CSF-led initiatives for non-Fund employees: the Suppliers Code of Conduct and the Visitors Code of Conduct.
- Input for Anti-Fraud and Anti-Corruption Policy (AFAC):
  - Consulted on and provided input for the AFAC, which came into effect in early December as part of the 2024 Staff Handbook update.
  - Ethics Office provided input to link AFAC to the existing Ethics Framework, particularly requirements to avoid, disclose and address conflicts of interest.

### Ethics Office Contributions to Shaping AI at the Fund
- Consulted on and provided input for the Fund’s internal Guidance for Responsible Use of Internal AI Tools to ensure ethical parameters and adherence to the Fund’s Rules on Staff Code of Conduct and Core Values.
- Emphasis in guidance on fairness, non-discrimination, and respect; alignment with existing policies on harassment and discrimination.
- Participated in the Copilot Air Marshal Program with ITD to support ethical use of generative AI tools like Copilot 365 and to provide tailored guidance for internal AI users.

### Policy Initiatives Planned
- Updating the IMF Code of Conduct and the Framework on Financial Disclosure and Conflict of Interest:
  - CY2025/26 identified as appropriate timeframe to engage in broader ethics policy reviews.
  - Reviews will require strategic reconsideration of institutional challenges and risks, interlinking with other elements of the Ethics framework.
  - Reviews will require consultation with multiple internal stakeholders and ideally a benchmarking assessment of best practices in other IFIs.

### Compliance Work Streams
- 2024 Financial Disclosure Program (FDP) administration and enhancements:
  - Ethics Office assumed management of FDP administration in 2024, serving as contract manager and primary liaison with External Compliance Advisor, KPMG.
  - Participating staff include those at the A-15 level in area departments, COM, LEG, MCM, and SPR, in addition to all B-level staff and A-level staff in CSF, FIN, and INV, as identified by each department.
  - Enhancements implemented in 2023 continued in 2024, including publication of summary statements of interests and activities for the MD and DMDs.
  - The 2024 FDP covered the calendar year 2023 and included a total of 647 individuals as staff filers.
  - The Fund achieved a 100% participation rate through timely submissions and no late submissions.
  - Of submissions, 20 were brought by KPMG to the Ethics Office for discussion:
    - finding of no actual conflict of interest in 1 case,
    - potential conflict of interest in 4 cases,
    - apparent conflict of interest in 15 cases,
    - no conflict of interest of any type in 1 case.
- Completed Request for Proposal (RFP) process for the Fund’s External Compliance Advisor:
  - RFP process initiated in 2022 and recommended by an internal evaluation panel in 2023 was completed in 2024.
  - New External Compliance Advisor role is expanded with increased reporting requirements to strengthen transparency and conflict-of-interest avoidance.
- Designated Officer role development:
  - Ethics Advisor has served as the Financial Conflict of Interest Designated Officer for the Investment Oversight Committee for ten years (interim appointment in 2014; permanent in 2018).
  - Terms of Reference for the Designated Officer were approved by Management in 2023.
  - In 2024, Ethics Office worked with LEG and FIN on a Bright Lines Rule memo to strengthen the institutional conflicts framework.
  - Further implementation of Designated Officer role elements to continue in 2025.
- 2024 Ethical Conduct and Core Values Certification:
  - Carried out in 2024 Q3 via Workday portal.
  - A total of 4,242 Fund staff and long-term contractual employees worldwide, in HQ and overseas offices, were asked to certify that they have read and understood the Fund’s Ethics framework, will comply with it, and will act in accordance with the Fund’s Core Values.
  - The final overall compliance rate was 99.2%.
  - 18 out of the 27 departments/offices reached 100% compliance.
  - This represents an increase from the 2023 final overall compliance rate of 98%.
- Ethics Office participation in IMF Integrity Hotline Oversight Committee:
  - IMF Integrity Hotline is a confidential, anonymous service available online worldwide and by phone in North America; operated by an independent external service provider.
  - Ethics Office promotes Hotline in outreach and training.
  - Ethics Advisor is an ex officio member of the Oversight Committee; Director of HRD is Chair; OII serves as Secretariat; other ex officio members include Directors of FIN, LEG, and OIA, and a SAC appointee (not a current SAC member).
  - Oversight Committee receives and reviews three reports per year; annual report on operations goes to the Managing Director.
  - In 2024, the Ethics Advisor attended three meetings of the Oversight Committee.
- Ethics Office participation in the Domestic Abuse Prevention Program:
  - Fund’s Committee on the Prevention of Domestic Abuse created in 2012; includes representatives from Ethics Office, OII, LEG, Security Services within CSF, Human Resources Department, and the Counseling Unit of HSD.
  - In 2024, Ethics Office was formally consulted on six DAPP matters.
  - Ethics Office supported HRD’s efforts to update the Committee’s terms of reference and stands ready to continue support in 2025.

### Process Optimization and Culture Change Contributions
- Process optimization:
  - Began digitizing advice and guidance records in 2024 to explore internal use of AI tools, aiming to enhance speed and consistency of internal advice and guidance.
  - Plans to continue these efforts in CY 2025 aligned with Fund-wide initiatives and record management strategies.
- Continued contribution to Culture Change Initiative:
  - Under Implementation Plan for the ISR, D&I Office leads culture change; Ethics Office plays a supporting role.
  - Ethics Office co-prepared Ask Me Anything session on culture change and positive workplace in June 2024.
  - Plans to collaborate closely with D&I Office, COM, and the Mediation Office on joint communications and focus groups.
  - Intends to roll out additional e-learning micro-learning tools in CY2025/2026 to enhance situational awareness and bystander intervention.

### Outreach and Ethics in a Polarized Context
- Navigating the 2024 Super Election Year:
  - 2024: half of the world’s population—some 3.7 billion people—had the opportunity to go to the polls in 72 countries (UNDP statistic referenced).
  - Ethics Office increased outreach to raise awareness of the need to preserve independence and impartiality in professional and personal lives where public statements are involved.
  - Re-issued guidance note on Standards of Conduct Related to Political Activities and Public Statements; co-organized Ask Me Anything on Standards of Conduct and the Ethics Rules in a Digital and Polarized World.
  - Included case studies in Mandatory Ethics Training and provided proactive advice where non-compliance was apparent, particularly regarding personal social media use.
- Supporting colleagues internally amid polarization:
  - Organized internal brown bag lunch with a Mediation Office ad hoc mediator on “Political Conflict and its Impact on the Workplace.”
  - Ethics Advisor encouraged departmental management to consider mediation or facilitation to overcome divisions.
  - Ethics Advisor worked with the D&I Officer to brainstorm support measures for colleagues facing polarization-related issues.

### The Fund’s Core Values (as stated)
- EXCELLENCE: strive for excellence; highest professional standards for common public good.
- HONESTY: tell the truth; straightforward and honest; follow through on commitments.
- IMPARTIALITY: objective, neutral, and impartial; professional judgment not influenced by partisan politics, outside authorities or personal bias.
- INCLUSION: value diversity; build diverse networks and teams; do not tolerate discrimination.
- INTEGRITY: do what is right for members, communities, the Fund, and each other; do not compromise values.
- RESPECT: treat colleagues with courtesy and respect; no harassment, physical or verbal abuse.

*International Monetary Fund Ethics Office — Annual Report 2024, Sections 5, 2, and 3*

### SECTION 5

### SECTION 5 LOOKING AHEAD

### Message from the Ethics Advisor — Key takeaways
- The Ethics Office adapted to a hybrid workplace while operating amid polarization, significant geopolitical tensions, and persistent macroeconomic uncertainties.
- The Ethics Office organized or participated in a total of 114 live outreach or training sessions, delivered either in person or remotely.
- Those sessions reached more than 3170 Fund colleagues, representing 75% of all Fund employees worldwide.
- The Ethics Office contributed to the development of Responsible AI at the Fund.
- The Ethics Office expanded responsibilities for the Fund’s Financial Disclosure Program.
- The Ethics Office responded to 565 requests for advice and guidance in 2024 — the highest recorded number so far.
- Leadership transitions noted: Ombudsperson Ms. Ellen Connors and Head of the Office of Internal Investigations Mr. Patrice Sam succeeded prior office-holders.

### Overview of Advice Categories and 2024 caseload — structure and distribution
- Key Ethics Issues identified by the Ethics Office include:
  - Obligations as an International Civil Servant
  - External Activities
  - Discrimination; Unfair Preferential Treatment/Bias
  - Publications, Public Statements, and Copyright
  - Gifts and Awards
  - Financial Conflicts of Interest
  - Harassment; Retaliation
  - Misuse of Resources and Non-Public Info
  - Personal Conflicts of Interest
  - Political Activities
  - Post-Fund Employment
  - Household Obligations
- Annual advisory matters by category (2019–2024) — selected 2024 figures and shares:
  - Total recorded advisory matters in 2024: 565
  - Obligations as an International Civil Servant: 56 requests, 9.9 percent
  - Financial Conflicts of Interest: 38 requests, 6.7 percent
  - Personal Conflicts of Interest: 49 requests, 8.7 percent
  - Gifts and Awards: 39 requests, 6.9 percent
  - Political Activities: 12 requests, 2.1 percent
  - Post-Fund Employment: 8 requests, 1.4 percent
  - External Activities: 277 requests, 49.0 percent
  - Publications, Public Statements, and Copyright: 9 requests, 1.6 percent
  - Misuse of Resources & Non-Public Information: 17 requests, 3.0 percent
  - Discrimination: 5 requests, 0.9 percent
  - Harassment: 36 requests, 6.4 percent
  - Household Obligations: 2 requests, 0.4 percent
  - Retaliation: 0 requests, 0.4 percent (note: source reports "1130020.4" across years formatting retained where presented)
  - Unfair Preferential Treatment/Bias: 4 requests, 0.5 percent

### 2024 advice matters — trends and analysis
- Year-on-year dynamics:
  - Overall number of recorded requests increased by almost 40% compared to 2023.
  - 2024 requests exceeded the previously highest annual total (CY 2019 with 507 recorded requests) by more than 10%.
- Areas with the largest absolute and relative increases from 2023 to 2024:
  - Obligations as International Civil Servants: 56 in 2024 vs. 30 in 2023 (9.9% in 2024 vs. 7.4% in 2023).
  - Personal Conflicts of Interest: 49 in 2024 vs. 27 in 2023 (8.7% vs. 6.7%).
  - Political Activities: 12 in 2024 vs. 4 in 2023 (2.1% vs. 1%).
  - Harassment: 36 in 2024 vs. 17 in 2023 (6.4% vs. 4.2%).
- External activity approval requests:
  - Review of external activity approvals continues to constitute around half of all questions to the Ethics Office.
  - The number of queries in this area continues to increase though the percentage share remains mostly the same.
  - The Ethics Advisor identifies process optimization (for example, through AI tools) as most needed and most promising for this area.
  - Methodology change in 2024: the Ethics Office began counting a prior staff request submitted before HRD consultation as a separate matter even if related to the same activity; in 2024 there were 17 such cases out of a total of 277 consultations related to external activity approval requests.

### Overview of training delivery models and workstreams — Mandatory Ethics Training (MET)
- Completion of Fund-wide in-person MET workshop style started mid-2022:
  - In 2024, the Ethics Office completed the Fund-wide roll-out by delivering the MET to the remaining eight departments: MCM, SPR, FAD, STA, RES, FIN, SEC, and OMD.
  - All members of senior management, including the Managing Director, attended the OMD session.
  - To deliver MET to these eight departments, Ethics Office staff held a total of 40 sessions.
  - Attendance for those 40 sessions: 1936 Fund staff and long-term contractual employees at Fund headquarters.
- Next steps:
  - The Ethics Office will take stock of the MET effort in 2025, further analyze feedback and survey responses, share Fund-wide responses to FAQs received during sessions on common ethics topics, and restart the next MET cycle in 2026.

*International Monetary Fund Ethics Office — Annual Report 2024, Section 5*

### SECTION 2

### SECTION 2 — TRAINING AND OUTREACH

### Relaunch of e-Learning Ethics Course on Positive Workplace
- The Ethics Office launched a post-pandemic update of the mandatory e-learning course, Positive Workplace—Preventing Harassment at Work, in June 2024.
- The refresh builds on the previous update from 2021 and incorporates insights from the Institutional Safeguards Review and the post-pandemic transition to hybrid work.
- Course design and objectives:
  - Designed as a concise 40-minute training.
  - Equips Fund employees at all levels with essential knowledge, practical tools, and accessible resources to identify and address inappropriate behaviors early, prevent all forms of harassment, and access avenues for support.
  - Includes bespoke scenarios intended to be realistic and relevant for everyone across the Fund; scenarios emphasize that harassment can occur in both in-person and virtual settings.
- Uptake:
  - At the end of 2024, approximately 94% of staff and long-term contractual employees have completed the training.

### Ethics Induction for New Joiners: Evolving Format
- Delivery in 2024:
  - The Ethics Office delivered 21 ethics induction sessions as part of HRD’s bi-weekly Onboarding briefing.
  - Sessions were mostly hybrid; two Ethics Office team members were present in-person on almost all dates.
  - These sessions covered approximately 382 new Fund employees.
- Onboarding format changes in Q4 2024:
  - HRD divided Onboarding into the bi-weekly New Employee Onboarding briefing and the monthly Onboarding “IMF Essentials” event.
  - As part of the bi-weekly Onboarding, HRD delivered a brief overview presentation on behalf of and prepared by the Ethics Office; by the end of CY2024, this presentation has been provided in three sessions to 37 new Fund employees.
  - The Ethics Office’s “Ethics and Values” presentation became part of the monthly HRD Onboarding “IMF Essentials” event; the Ethics Office delivered two ethics induction sessions in two “IMF Essentials” events to approximately 27 new Fund employees.
- Aggregate reach:
  - Taking all induction sessions together, the Ethics Office reached and connected with over 400 new Fund employees during a total of 23 in-person sessions.

### Ethics Briefings and Targeted Training
- Resident Representatives (Res Reps):
  - In 2024, the Ethics Office briefed seventeen new Res Reps prior to their assignments.
  - Briefings reviewed key ethics issues likely to arise in the field and addressed additional affirmative obligations under the Fund’s Standards of Conduct for managers.
- Ethics Training for Executive Board Members:
  - Training was delivered in 2024 for the second time, following the Board Ethics Committee recommendation and the Board’s 2022 approval as part of the Implementation Plan in Response to IMF Executive Board and Management Endorsed Recommendations of the 2022 Institutional Safeguards Review; the session was well received and well attended.
- Ad hoc on-demand sessions:
  - The Ethics Advisor delivered ad hoc ethics training and awareness sessions upon departmental request, including:
    - Attendance at a roleplay-based anti-harassment workshop organized by APD.
    - A presentation on dispute resolution offerings to TRM.
    - A presentation on the Ethics Office mandate for ORM’s monthly enterprise risk community meeting.
    - Two brown bag lunches for HRD colleagues on workplace behavior challenges.
    - Two sessions for ICD leadership and managers on proactively managing performance while avoiding behavior that could trigger allegations of harassment.

### Outreach to PRWs and SHRPs; Staff Pulse Survey Follow-Up
- At the Mediation Office’s request, the Ethics Advisor held one Ethics training and awareness session for new PRWs in January 2024.
- Outreach to SHRPs and HRD stakeholders:
  - The Ethics Advisor held two brown bag lunches for HRD client-facing colleagues on addressing inappropriate workplace behavior by internal clients.
  - Discussions emphasized establishing boundaries and the importance of bystander intervention.
- The Ethics Advisor supported SHRPs and the D&I Office in follow-up efforts on the 2024 Staff Pulse Survey.

### Enhanced Outreach to Field Offices and Recommendations
- Field engagement activities in 2024:
  - In January 2024, at AFR management’s invitation, the Ethics Advisor attended the AFR Field Office Workshop and co-conducted a case study-based ethics workshop with OII for AFR Res Reps and RC Directors.
  - Conducted Mandatory Ethics Training for Resident Representatives and local economists in MCD at their retreat.
  - Presented at WHD Overseas Office Managers retreat and WHD Res Rep retreat before the Spring Meetings.
  - Provided virtual sessions for SARTTAC, AFRITAC South and ATI, the Mauritania Res Rep Office, and the Honduras Res Rep Office (the latter delivered in Spanish).
  - Presented in-person at the WHD retreat for office managers in March 2024, at the Local Security Coordinators Retreat in March 2024, at STA’s working visit for LTX in May 2024, and at an AFR onboarding session for new Res Reps in June 2024.
  - Briefly introduced the Ethics Office at the RCDC Retreat organized by ICD in November 2024.
- Recommendation to leadership:
  - The Ethics Advisor strongly recommends that all heads of departments and offices inform and invite the Ethics Office whenever they bring groups of field-based staff and employees for workshops or retreats to Headquarters, to use HQ-based events as opportunities for in-person stand-alone training given higher ethics and integrity risk profiles outside Headquarters.
- Forward plan:
  - Going forward in 2025, the Ethics Office will continue to enhance outreach to Fund field offices and explore ways to strengthen field office leadership engagement.

### Expanded Ethics Office Open House and Internal Communications
- Open House (“I♥ Ethics”):
  - The Ethics Office hosted its Annual Open House in its 12th year on February 14 and 15, spanning two days at HQ2 and HQ1.
  - To ensure inclusivity, the Open House ran in both in-person and virtual formats with three virtual sessions offered in English, French, and Spanish.
  - Virtual sessions included a brief presentation on the Office’s mandate, key highlights from the 2023 Annual Report, and enhanced outreach/internal communication efforts; ample time was allocated for Q&A.
  - The Ethics Office plans to host the next Open House on February 19 and 20, 2025, in a hybrid format to mark its 25th anniversary, with a more comprehensive and substantive program.
- Ask Me Anything (AMA) sessions and other visibility efforts:
  - The Ethics Office co-organized three AMA sessions in collaboration with other departments:
    - One focused on fostering a positive workplace, held with the D&I Office and the SAC, tied to the Positive Workplace e-learning relaunch.
    - One addressed public statements, personal social media use, and participation in political activities as international civil servants, co-hosted with COMIN.
    - In December, a session on the updated Gifts and Hospitality Policy was co-hosted with HRD and CSF.
  - The Ethics Office intends to continue AMA sessions on a quarterly basis.
  - The Ethics Advisor participated in the Get to Know (G2K) Series at COM and CSF.
  - The Ethics Office published blogs and intranet stories throughout the year to inform and engage employees.
- Intranet page update:
  - The Ethics Office conducted a comprehensive review and analysis of its intranet page and made targeted improvements to visual design and functionality.
  - Completed a content mapping exercise to support transition as part of the Fund-wide migration to SharePoint Online, scheduled for the second half of 2025; additional updates are planned following the completion of the migration.

### Peer Learning for and with the Ethics Office
- ENMO participation and Standards of Practice:
  - The Ethics Office is a member of the Ethics Network of the Multilateral Organizations (ENMO), a network of ethics function representatives from over 55 international organizations and international financial institutions.
  - Since 2022, ENMO has been developing “Standards of Practice” for Ethics functions; throughout 2024, the Ethics Advisor actively participated in drafting and development, with adoption expected in 2025.
  - ENMO’s annual conference in 2024 was hosted by the World Health Organization in Geneva; the Ethics Advisor led a session on lessons learned.
- Regional and institutional peer engagements:
  - The Ethics Office presented in an IFI working group session on the Fund’s institutional conflict of interest framework, discussing advisory versus compliance functions and overlaps between institutional and personal conflicts of interest.
  - Since February 2023, the Ethics Advisor is co-chair of the CEB Chapter of ENMO, organizing and co-leading quarterly virtual meetings and a career networking event for junior staff.
  - The Ethics Office organized and participated in two brown bag lunches with Ethics colleagues from the World Bank and the IADB.
  - At the ECB’s invitation, the Ethics Advisor presented in April 2024 on the role of the IMF’s Ethics Advisor in contributing to good governance and high ethical standards.
  - In October 2024, the Ethics Advisor attended and presented at a virtual event marking the 20th anniversary of the European Investment Bank’s Ethics Office on balancing Ethics function independence with relevance.
  - Ethics Office staff co-presented with LEG at the MDB Symposium on Conflicts of Interest in September, hosted by the EBRD in London, focusing on the Fund’s institutional conflict of interest framework and the Designated Officer role.
  - The Ethics Office hosted a visit in September by the Ethics Office of the Central Bank of Malaysia for professional exchange.

*Source: SECTION 2 — TRAINING AND OUTREACH, Ethics Office Annual Report 2024.*

### SECTION 3

### SECTION 3 — POLICY DEVELOPMENT AND COMPLIANCE WORK STREAMS

### Policy Development Work Streams
- Ethics Office involvement in the Implementation Plan for the Institutional Safeguards Review (ISR):
  - Consulted on several ISR-related policy initiatives, notably the review and update of the Code of Conduct for the Members of the Executive Board.
  - The Office of the General Counsel led the review as Secretary to the Board Ethics Committee; the Ethics Advisor met with the Board Ethics Committee on several occasions.
  - The revised Code of Conduct for the Members of the Executive Board came into effect on October 1, 2024.
- Revised Gift and Hospitality Policy and 2024 Staff Handbook update:
  - Ethics Office led revisions to the Fund’s policy on accepting gifts, decoration, awards and honors offered in connection with one’s Fund service.
  - Revisions aimed to clarify approaches to gifts and awards while maintaining the Fund’s Core Values of impartiality and integrity and the importance of independence.
  - Policy revisions included a new provision addressing hospitality offered in connection with Fund service and a recommendation that the policy be used by staff in certain roles with counterparts to preemptively avoid issues.
  - The Ethics Office organized and participated in an Ask Me Anything Session after the early December publication of the new policy and prior to the year-end gift giving season.
  - The Ethics Office provided input on other Staff Handbook revisions, including the new Anti-Fraud and Anti-Corruption Policy.
- Input for Supplier Code of Conduct and Visitors Code of Conduct:
  - Ethics Office consulted on CSF-led initiatives for non-Fund employees: the Suppliers Code of Conduct and the Visitors Code of Conduct.
  - The Office welcomed and supported these initiatives as they reflect IFI community good practice and reduce employee exposure to ethics and integrity risks.
- Input for Anti-Fraud and Anti-Corruption Policy (AFAC):
  - Ethics Office consulted on and provided input for the AFAC, which came into effect in early December as part of the 2024 Staff Handbook update.
  - LEG and OII led drafting; Ethics Office provided input to link AFAC to the existing Ethics Framework, particularly requirements to avoid, disclose and address conflicts of interest.

### Ethics Office Contributions to Shaping AI at the Fund
- Ethics Office role in Fund-wide AI initiatives:
  - Consulted on and provided input for the Fund’s internal Guidance for Responsible Use of Internal AI Tools to ensure ethical parameters and adherence to the Fund’s Rules on Staff Code of Conduct and Core Values.
  - Emphasis in guidance on fairness, non-discrimination, and respect; alignment with existing policies on harassment and discrimination.
  - Ethics Office staff participated in the Copilot Air Marshal Program with ITD to support ethical use of generative AI tools like Copilot 365 and to provide tailored guidance for internal AI users.

### Policy Initiatives Planned
- Updating the IMF Code of Conduct and the Framework on Financial Disclosure and Conflict of Interest:
  - CY2025/26 identified as appropriate timeframe to engage in broader ethics policy reviews.
  - Reviews will require strategic reconsideration of institutional challenges and risks, interlinking with other elements of the Ethics framework.
  - Reviews will require consultation with multiple internal stakeholders and ideally a benchmarking assessment of best practices in other IFIs.

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### Compliance Work Streams
- 2024 Financial Disclosure Program (FDP) administration and enhancements:
  - Ethics Office assumed management of FDP administration in 2024, serving as contract manager and primary liaison with External Compliance Advisor, KPMG.
  - Participating staff include those at the A-15 level in area departments, COM, LEG, MCM, and SPR, in addition to all B-level staff and A-level staff in CSF, FIN, and INV, as identified by each department.
  - Enhancements implemented in 2023 continued in 2024, including publication of summary statements of interests and activities for the MD and DMDs.
  - The 2024 FDP covered the calendar year 2023 and included a total of 647 individuals as staff filers.
  - The Fund achieved a 100% participation rate through timely submissions and no late submissions.
  - Of submissions, 20 were brought by KPMG to the Ethics Office for discussion:
    - finding of no actual conflict of interest in 1 case,
    - potential conflict of interest in 4 cases,
    - apparent conflict of interest in 15 cases,
    - no conflict of interest of any type in 1 case.
- Completed Request for Proposal (RFP) process for the Fund’s External Compliance Advisor:
  - RFP process initiated in 2022 and recommended by an internal evaluation panel in 2023 was completed in 2024.
  - New External Compliance Advisor role is expanded with increased reporting requirements to strengthen transparency and conflict-of-interest avoidance.
  - Ethics Office played a key part throughout the RFP due to its conflicts of interest expertise and expanded FDP responsibilities.
- Designated Officer role development:
  - Ethics Advisor has served as the Financial Conflict of Interest Designated Officer for the Investment Oversight Committee for ten years (interim appointment in 2014; permanent in 2018).
  - Terms of Reference for the Designated Officer were approved by Management in 2023.
  - In 2024, Ethics Office worked with LEG and FIN on a Bright Lines Rule memo to strengthen the institutional conflicts framework.
  - Ethics Office staff co-presented with LEG at the MDB Symposium on Conflicts of Interest in September in London.
  - Further implementation of Designated Officer role elements to continue in 2025.
- 2024 Ethical Conduct and Core Values Certification:
  - Carried out in 2024 Q3 via Workday portal.
  - A total of 4,242 Fund staff and long-term contractual employees worldwide, in HQ and overseas offices, were asked to certify that they have read and understood the Fund’s Ethics framework, will comply with it, and will act in accordance with the Fund’s Core Values.
  - The final overall compliance rate was 99.2%.
  - 18 out of the 27 departments/offices reached 100% compliance.
  - This represents an increase from the 2023 final overall compliance rate of 98%.
- Ethics Office participation in IMF Integrity Hotline Oversight Committee:
  - IMF Integrity Hotline is a confidential, anonymous service available online worldwide and by phone in North America; operated by an independent external service provider.
  - Ethics Office promotes Hotline in outreach and training (Resident Representative briefings, ethics inductions, mandatory online Ethics course “Positive Workplace” re-launched in 2024, Mandatory Ethics Training).
  - Ethics Advisor is an ex officio member of the Oversight Committee; Director of HRD is Chair; OII serves as Secretariat; other ex officio members include Directors of FIN, LEG, and OIA, and a SAC appointee (not a current SAC member).
  - Oversight Committee receives and reviews three reports per year; annual report on operations goes to the Managing Director.
  - In 2024, the Ethics Advisor attended three meetings of the Oversight Committee.
- Ethics Office participation in the Domestic Abuse Prevention Program:
  - Fund’s Committee on the Prevention of Domestic Abuse created in 2012; includes representatives from Ethics Office, OII, LEG, Security Services within CSF, Human Resources Department, and the Counseling Unit of HSD.
  - In 2024, Ethics Office was formally consulted on six DAPP matters.
  - Ethics Office supported HRD’s efforts to update the Committee’s terms of reference and stands ready to continue support in 2025.

### Process Optimization and Culture Change Contributions
- Process optimization:
  - Began digitizing advice and guidance records in 2024 to explore internal use of AI tools, aiming to enhance speed and consistency of internal advice and guidance.
  - Plans to continue these efforts in CY 2025 aligned with Fund-wide initiatives and record management strategies.
- Continued contribution to Culture Change Initiative:
  - Under Implementation Plan for the ISR, D&I Office leads culture change; Ethics Office plays a supporting role.
  - Ethics Office co-prepared Ask Me Anything session on culture change and positive workplace in June 2024.
  - Plans to collaborate closely with D&I Office, COM, and the Mediation Office on joint communications and focus groups.
  - Offer training for new PRWs at Mediation Office request; intends to roll out additional e-learning micro-learning tools in CY2025/2026 to enhance situational awareness and bystander intervention.

### Outreach and Ethics in a Polarized Context
- Navigating the 2024 Super Election Year:
  - 2024: half of the world’s population—some 3.7 billion people—had the opportunity to go to the polls in 72 countries (UNDP statistic referenced).
  - Ethics Office increased outreach to raise awareness of the need to preserve independence and impartiality in professional and personal lives where public statements are involved.
  - Re-issued guidance note on Standards of Conduct Related to Political Activities and Public Statements; co-organized Ask Me Anything on Standards of Conduct and the Ethics Rules in a Digital and Polarized World.
  - Included case studies in Mandatory Ethics Training and provided proactive advice where non-compliance was apparent, particularly regarding personal social media use.
- Supporting colleagues internally amid polarization:
  - Organized internal brown bag lunch with a Mediation Office ad hoc mediator on “Political Conflict and its Impact on the Workplace.”
  - Ethics Advisor encouraged departmental management to consider mediation or facilitation to overcome divisions.
  - Ethics Advisor worked with the D&I Officer to brainstorm support measures for colleagues facing polarization-related issues.

### The Fund’s Core Values (as stated)
- EXCELLENCE: strive for excellence; highest professional standards for common public good.
- HONESTY: tell the truth; straightforward and honest; follow through on commitments.
- IMPARTIALITY: objective, neutral, and impartial; professional judgment not influenced by partisan politics, outside authorities or personal bias.
- INCLUSION: value diversity; build diverse networks and teams; do not tolerate discrimination.
- INTEGRITY: do what is right for members, communities, the Fund, and each other; do not compromise values.
- RESPECT: treat colleagues with courtesy and respect; no harassment, physical or verbal abuse.

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_Source: https://www.imf.org/-/media/files/about/ethics/annual-report/eoar2024.pdf_