## eoar2025

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---

### SECTION 5 — LOOKING AHEAD: Context, trends, and near-term priorities
- Context and institutional priorities
  - In 2025, macroeconomic uncertainties and geopolitical tensions increased, accelerating trends observed since 2024 and the years following the pandemic.
  - The Fund’s Core Values—integrity, respect, impartiality, honesty, inclusion, and excellence—remain central to the Ethics Office’s work, "especially, and even more so, when these values are put into question."
  - The 25th anniversary of the Fund’s Ethics Office was celebrated in February 2025 under the topic “25 Years IMF Ethics Office – Values in Action.”
  - An updated version of the Ethics Advisor’s Terms of Reference is envisaged to be issued in 2026 to reflect an expanded mandate and additional responsibilities.

- Advice and guidance — 2025 caseload, trends, and implications
  - Total requests for advice and guidance in 2025: 566.
  - Total requests for advice and guidance in 2024: 565.
  - Interpretation: The number of requests stabilized at a high level; 2024 marked an all-time high since the Ethics Office was established in 2000. The Ethics Office views the sustained high demand as evidence of increased awareness among Fund employees of the ability to seek confidential advice and guidance.
  - Areas with notable increases in 2025 (absolute and relative):
    - Personal conflicts of interest: 62 requests in 2025, compared to 49 requests in 2024, making up 11% of all requests in 2025, compared to 8.7% in 2024.
    - External activities: 308 requests in 2025, compared to 277 in 2024, making up 54.4% of all requests in 2025, compared to 49% in 2024.
  - Area with a notable decrease in 2025:
    - Harassment or alleged harassment: 13 requests in 2025, compared to 36 requests in 2024. The Ethics Office notes 2023 request numbers were similar to 2025, so 2024 may have been an outlier.
  - Organizational implication: A stabilized high number of requests can create resource capacity issues for the Ethics Office.

- Key operational priorities and tools
  - The Ethics Office remained proactive in contributions to Fund-wide AI initiatives to ensure ethical integration of new technology into institutional operations and decision-making; efforts focused on collaboration and contributions guided by the Office’s mandate to align AI use with the Fund’s values and ethical standards.
  - To address capacity pressures, the Ethics Office is actively exploring the creation of a suitable AI tool to assist the team internally with preparing first drafts of advice and guidance, particularly for relatively routine topics.
  - The Ethics Office expects an active 2026 with several policy revision projects and the relaunch of the Fund-wide in-person Mandatory Ethics Training (MET) underway for 2026.
  - The Ethics Office emphasizes continued proactive engagement and open dialogue with Fund employees and reaffirms availability: "we have your back."

### SECTION 2 — TRAINING AND OUTREACH: Delivery models, outreach, and engagement
- Overview of training delivery models and work streams
  - Virtual training
    - The mandatory e-learning course “Navigating Ethics: Conflicts of Interest” was updated in May 2025.
    - Course length: 20-minute course.
    - Update reflects recent revisions to the Staff Handbook, particularly the updated gifts and hospitality policy.
  - Mandatory in-person ethics induction for new joiners
    - HRD Onboarding included a brief Ethics Office overview in its bi-weekly Onboarding briefing delivered to approximately 463 new Fund employees across 25 sessions during 2025.
    - Ethics Office delivered 12 ethics induction sessions focused on “Ethics and Values” as part of the monthly HRD Onboarding “IMF Essentials” event.
    - Format: hybrid, with two Ethics Office team members present in-person at each session to facilitate engagement.
    - Total engagement in 2025 with new joiners: approximately 463 new Fund employees during a total of 37 sessions.
  - Mandatory pre-departure briefings for Resident Representatives (Res Reps)
    - The Ethics Office delivered 13 pre-departure ethics briefings in 2025 for Res Reps prior to the start of assignments.
    - Format: in-person whenever possible or one-on-one Teams meetings when not.
    - Briefings covered role as head of office and Fund representative, affirmative managerial obligations under the Fund’s Standards of Conduct, and new obligations under the Fund’s Anti-Fraud and Anti-Corruption (AFAC) Policy.
    - The Ethics Office organized an AMA webinar in 2025 on the new AFAC Policy with a Regional Technical Assistance Centers Director as panelist.
  - Outreach for Long-Term Experts (LTX)
    - Delivered a total of 14 individual ethics briefings for newly recruited LTXs during onboarding week.
    - Q1 presentations: Institute for Capacity Development’s LTX retreat attended by 24 LTX; Fiscal Affairs Department’s LTX retreat attended by about 200 Fund employees, including about 100 LTXs; Monetary and Capital Markets Department group call attended by 31 LTX.
    - Particular focus in 2025 LTX briefings: private use of social media and other online engagements by LTXs.
  - On-demand and in-reach training for HQ leadership and managers
    - On-demand in-person ethics training for HQ-based employees focused on political activities, private social media use, and reporting alleged misconduct while emphasizing constructive performance management.
    - Delivered a total of 18 in-person in-reach sessions (Ethics Office with Communications Department) for senior management teams of all headquarters-based offices and departments.
    - An additional session was held for the A1 to A8 Committee at their request.
    - Targeted sessions on reporting alleged misconduct (Ethics Office with OII) and on constructive performance management (Ethics Advisor with Ombudsperson and HRD) were held for managers in ITD, CSF, and SEC timed ahead of peak performance management cycle periods.
  - Ethics training for Executive Board members
    - During Q1 2025 the Ethics Advisor participated in and presented at the Board ethics training for Executive Directors and OED personnel; this was the third occurrence of the session in the regular ethics awareness program.
  - On-demand ethics training outside HQ
    - Virtual presentation at the Quarterly RCDC Directors Meeting (ICD) in Q1 during a case study-based joint session with DRS Heads and the Fund’s Diversity and Inclusion Advisor.
    - In-person and virtual sessions delivered in Dar es Salaam, Delhi, Riyadh, Beijing, and Japan; training provided for local employees at AFRITAC South, AFRITAC East, SARTAC, and the Fund’s new Regional Office in Riyadh.

- Outreach and communications highlights
  - Ethics Office Open House and 25th anniversary
    - Open House “I ♥ Ethics” marked its 13th consecutive edition and coincided with the Ethics Office’s 25th anniversary.
    - Institutional milestone: the Fund’s Ethics Office was established in early 2000; the Fund’s first Ethics Officer assumed duties on February 7, 2000.
    - Commemoration event: on February 19, 2025 the Fund hosted an interactive panel with internal and external subject matter experts; opening remarks by the Managing Director; panel topics included the Ethics Office’s role in shaping Fund culture.
    - Open House format: offered in-person and virtually; three virtual sessions organized to accommodate different time zones and offered in English, French, and Spanish.
  - AMA series and internal communications
    - Two AMA sessions hosted in 2025:
      - First session in May (co-organized with OII and LEG) focused on the Fund’s first New AFAC Policy.
      - Second session in December (co-organized with COM, HRD, and SAC) addressed giving, fundraising, and volunteering under the theme Doing Good While Doing the Right Thing during the Fund’s Giving Campaign.
    - AMA series allows non-attributable questions to foster openness and is intended to continue quarterly to reach colleagues globally.
    - Ethics Office expanded outreach via blogs and intranet stories on key ethics topics.
  - Engagement with Strategic HR Partners (SHRP) and PRWs
    - Continuous engagement with SHRPs to promote messages on private social media use and managerial obligations to report misconduct; SHRP outreach led to multiple on-demand departmental trainings.
    - Ethics Advisor provided ethics training and awareness raising for new Peers for a Respectful Workplace (PRWs) in Fall 2025 alongside the Ombuds Office, OII, and HRD.

- Peer learning and institutional engagement
  - ENMO participation and Standards of Practice
    - The Ethics Office participates in a network of ethics representatives from over 55 international organizations and IFIs known as ENMO.
    - ENMO adopted the “Standards of Practice” for ethics functions in 2025; the Ethics Advisor actively contributed to preparatory discussions and drafting.
    - ENMO 2025 annual conference hosted by the Asian Infrastructure Development Bank in Beijing: Ethics Advisor led a session on “Recent Ethics Initiatives, Developments, and Lessons Learned” and contributed to a panel on social media and political activities.
  - IFI Chapter co-chair role and ongoing meetings
    - In October 2025 the Ethics Advisor became co-chair of the IFI Chapter of ENMO.
    - As IFI Chapter Co-Chair, the Ethics Advisor co-led a quarterly virtual meeting in December 2025 to discuss updates to Standards of Conduct/Code of Ethics in two member organizations; quarterly meetings are expected to continue in 2026.
  - MDB symposium engagement and bilateral exchanges
    - Ethics Office engaged peer institutions through MDB compliance functions on institutional conflicts of interest in investments via virtual attendance and presentation at the MDB symposium in October 2025.
    - Hosted visits by ethics offices of two regional MDBs: Asian Infrastructure Investment Bank in May 2025 and Central American Bank for Economic Integration in August 2025.
    - Ethics Advisor met with representatives of the European Commission’s Directorate General of Human Resources to discuss good practices for promoting staff integrity and ethical behavior.

### SECTION 3 — POLICY DEVELOPMENT AND COMPLIANCE WORK STREAMS: Reviews, programs, and certifications
- Policy Development Workstreams: Review of the IMF Code of Conduct for Fund Staff
  - The Ethics Office started a review of the Staff Code of Conduct at the beginning of Q3, with completion expected in early 2026.
  - Review activities undertaken:
    - Analysis of existing staff survey data.
    - Stakeholder consultations.
    - External benchmarking amongst relevant comparator IFIs and other international organizations (with assistance of an external consultant).
  - Purpose and expected outcome:
    - Proposed updates and enhancements to the Staff Code of Conduct based on findings.
    - An evidence-based roadmap to strengthen clarity, accessibility, and trust in the Staff Code of Conduct and reinforce the Fund’s commitment to a positive and accountable workplace culture.

- Compliance Workstreams: 2025 Financial Disclosure Program (FDP)
  - Administration and management
    - The Ethics Office assumed full administration of the FDP in 2025, having served as contract manager and primary liaison with the Fund’s External Compliance Advisor, KPMG, beginning in 2024.
    - Ethics Office worked closely with KPMG to identify, address, and mitigate any conflict of interest.
  - Coverage and participation
    - The 2025 FDP covered the calendar year 2024 and included a total of 715 individuals as staff filers.
    - The Fund achieved a 100% participation rate.
    - Participating staff included A-15 level in area departments, COM, LEG, MCM, and SPR; all B-level staff; and A-level staff in CSF, FIN, and INV as identified by departments.
    - Participating staff use an electronic system for disclosing personal financial interests and transactions; the system was further enhanced in 2025 with respect to staff separating from the Fund.
    - Public summary statements of interests and activities for certain staff, including the MD and DMDs, have been published online annually since 2023.
  - FDP outcomes referred to the Ethics Office by KPMG
    - 28 submissions were brought to the attention of the Ethics Office for discussion.
    - Findings among those 28 submissions:
      - actual conflict of interest in 3 cases
      - potential conflict of interest in 7 cases
      - apparent conflict of interest in 17 cases
      - no conflict of interest in 1 case
  - Forward work
    - The Ethics Office is preparing a review of the Fund’s Framework on Financial Disclosure and Financial Conflict of Interest as part of its workplan, initiated in 2025 with benchmarking and information gathering, with work to continue to complete the review and make indicated revisions to ensure a strengthened framework in 2026.

- Designated Officer role and institutional conflicts framework
  - Role and tenure
    - The Ethics Advisor serves as the Financial Conflict of Interest Designated Officer for the Investment Oversight Committee.
    - Appointed by the MD; served in the role since 2014 (initially interim) and in a permanent capacity since 2018.
    - Terms of Reference for the role were approved by Management in 2023.
    - Ethics Office collaborates closely with LEG and FIN in carrying out the role.
  - 2025 highlights and forward plans
    - Full implementation of the 2024 Bright Lines Rule memo to strengthen the institutional conflicts framework.
    - Ethics Office staff co-presented virtually with LEG staff at the MDB Symposium on Conflicts of Interest in October in Manila, Philippines.
    - Efforts to standardize elements of the Designated Officer role will be undertaken in 2026, in part in anticipation of the quinquennial conflicts of interest review in 2027.

- 2025 Ethical Conduct and Core Values Certification
  - Administration
    - Administered in the third quarter of 2025 by the Ethics Office through the Fund’s Workday portal; this was the fifth time the mandatory Certification was administered through Workday.
  - Coverage and compliance
    - A total of 4,409 Fund staff and long-term contractual employees worldwide were asked to certify.
    - Final overall compliance rate for the 2025 Certification was 99.6%.
    - 21 out of the 25 departments/offices reached 100% compliance.
    - This represents an increase from the 2024 final overall compliance rate of 99.2%.
  - Additional activity
    - The Ethics Office addressed over 30 substantive queries related to the 2025 Certification.

- IMF Integrity Hotline oversight and Domestic Abuse Prevention Program (DAPP)
  - IMF Integrity Hotline
    - The Hotline was established in 2008 as a confidential and anonymous reporting service, available online globally and by phone in North America.
    - The Hotline is operated by an independent external service provider through secure web servers and telephone contact centers.
    - The Ethics Advisor is an ex officio member of the Oversight Committee; the Director of HRD is the Chair; OII serves as Secretariat.
    - The Oversight Committee receives and reviews three reports per year on the Hotline’s operations, with an annual operations report submitted to the MD.
    - The Ethics Advisor attended three meetings of the IMF Integrity Hotline Oversight Committee in 2025.
  - Domestic Abuse Prevention Program (DAPP)
    - The Fund’s Committee on the Prevention of Domestic Abuse was established in 2012 and includes representatives from the Ethics Office, OII, LEG, Security Services within CSF, HRD, and the Counseling Unit of the Bank/Fund Health and Safety Directorate (HSD).
    - The Ethics Office was formally consulted on three DAPP matters in 2025.
    - The Ethics Office supported HRD in streamlining the Committee’s work, updating the Guidelines for Addressing Domestic Abuse, and engaging with the DAPP Manager and DAPP Coordinator at the World Bank.
    - The Ethics Office will remain involved in planned improvements to the Fund’s Domestic Abuse Program in 2026.

- MET relaunch, AI engagement, and forward-looking initiatives
  - MET prior cycle and review
    - The Ethics Office completed the fourth cycle of Fund-wide, in-person MET at the end of 2024: 97 sessions delivered, reaching a total of 4,036 staff members and long-term contractual employees.
    - In 2025, the Ethics Office conducted a comprehensive review of the MET program using internal qualitative and quantitative data and an external benchmarking assessment.
    - The next MET cycle is scheduled to resume in early 2026, aiming to use data-driven analysis, behavioral insights, and tailored content and delivery.
  - AI engagement
    - In 2025, the Ethics Office proactively contributed to the Fund’s internal work on AI and actively contributed to the 2025 updates to the IMF Responsible AI Use Guidelines.
    - Since January 2025, the Ethics Advisor has served as a member of the Fund’s AI Coordinating Committee.
  - Looking Ahead: Financial Disclosure Framework update
    - The Ethics Office included a review of the Fund’s Framework on Financial Disclosure and Financial Conflict of Interest in its 2026 workplan; following benchmarking undertaken in 2025, work will continue in 2026 to make appropriate revisions.

- Institutional values and reflection
  - The Fund’s Core Values (as stated): EXCELLENCE; HONESTY; IMPARTIALITY; INCLUSION; INTEGRITY; RESPECT.
  - Taking Stock: 25 Years of the IMF Ethics Office — Values into Action
    - The Ethics Office marked its 25-year anniversary in 2025; the first Ethics Advisor took office in February 2000.
    - The anniversary was observed in February 2025 with a panel discussion reflecting on the Ethics Office’s evolution and impact.
    - The MD underscored the importance of the Ethics Office and highlighted its contributions to good governance and maintaining high ethical standards.
    - Lessons from 25 years emphasize that upholding good governance and ethics is a collective responsibility at personal and institutional levels; given increased geopolitical and economic uncertainty in 2025, the Ethics function is characterized as needed more than ever within the Fund.

*Source: IMF Ethics Office — EOAR 2025, SECTION 2, SECTION 3, and SECTION 5.*

### SECTION 5

### SECTION 5 LOOKING AHEAD

### Context and institutional priorities
- In 2025, macroeconomic uncertainties and geopolitical tensions increased, accelerating trends observed since 2024 and the years following the pandemic.  
- The Fund’s Core Values—integrity, respect, impartiality, honesty, inclusion, and excellence—remain central to the Ethics Office’s work, "especially, and even more so, when these values are put into question."  
- The 25th anniversary of the Fund’s Ethics Office was celebrated in February 2025 under the topic “25 Years IMF Ethics Office – Values in Action.”  
- An updated version of the Ethics Advisor’s Terms of Reference is envisaged to be issued in 2026 to reflect an expanded mandate and additional responsibilities.

### Advice and guidance — 2025 caseload, trends, and implications
- Total requests for advice and guidance in 2025: 566.  
- Total requests for advice and guidance in 2024: 565.  
- Interpretation: The number of requests stabilized at a high level; 2024 marked an all-time high since the Ethics Office was established in 2000. The Ethics Office views the sustained high demand as evidence of increased awareness among Fund employees of the ability to seek confidential advice and guidance.  
- Areas with notable increases in 2025 (absolute and relative):
  - Personal conflicts of interest: 62 requests in 2025, compared to 49 requests in 2024, making up 11% of all requests in 2025, compared to 8.7% in 2024.  
  - External activities: 308 requests in 2025, compared to 277 in 2024, making up 54.4% of all requests in 2025, compared to 49% in 2024.  
- Area with a notable decrease in 2025:
  - Harassment or alleged harassment: 13 requests in 2025, compared to 36 requests in 2024. The Ethics Office notes 2023 request numbers were similar to 2025, so 2024 may have been an outlier.  
- Organizational implication: A stabilized high number of requests can create resource capacity issues for the Ethics Office.

### Key advice topics and issue framing
- The Ethics Office organizes advice according to Key Ethics Issues (examples listed by the Office):  
  - 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

### Training delivery models and workstreams
- Delivery approach in 2025: blend of virtual and in-person models for HQ and overseas employees.  
- Virtual training: ongoing ethics e-learning program that is mandatory for all Fund staff and long-term contractual employees; content is updated regularly.  
- In-person training: a mix of mandatory ethics training linked to certain employment life cycle events and on-demand training responding to requests from specific offices or departments.  
- In 2025 the Ethics Advisor responded to a significant increase in ad hoc on-demand ethics training sessions for management teams at HQ and overseas, with key focus areas:
  - Preserving independence and impartiality, especially when using social media.  
  - Meeting enhanced obligations for managers and staff to report alleged or suspected misconduct to the Fund’s Office of Internal Investigations (OII).  
- Internal communications and outreach in 2025 included blogs, intranet stories, and virtual Ask Me Anything (AMA) sessions open to all Fund colleagues.  
- The Ethics Office delivered joint outreach sessions, in person, virtually, and in hybrid formats, in collaboration with OII and the Ombuds Office.

### AI, tools, and internal support
- The Ethics Office remained proactive in contributions to Fund-wide AI initiatives to ensure ethical integration of new technology into institutional operations and decision-making; efforts focused on collaboration and contributions guided by the Office’s mandate to align AI use with the Fund’s values and ethical standards.  
- To address capacity pressures, the Ethics Office is actively exploring the creation of a suitable AI tool to assist the team internally with preparing first drafts of advice and guidance, particularly for relatively routine topics.

### Near-term outlook and planning
- The Ethics Office expects an active 2026 with several policy revision projects and the relaunch of the Fund-wide in-person Mandatory Ethics Training (MET) underway for 2026.  
- The Ethics Office emphasizes continued proactive engagement and open dialogue with Fund employees and reaffirms availability: "we have your back."

*Source: IMF Ethics Office — EOAR 2025, SECTION 5.*

### SECTION 2

### SECTION 2 — TRAINING AND OUTREACH

### Overview of training delivery models and work streams
- Virtual ethics training
  - The mandatory e-learning course “Navigating Ethics: Conflicts of Interest” was updated in May 2025.
  - Course length: 20-minute course.
  - Update reflects recent revisions to the Staff Handbook, particularly the updated gifts and hospitality policy.
  - Course purpose: guide Fund employees through scenarios inside and outside the workplace to prevent conflicts of interest and recognize when actual or perceived conflicts must be disclosed to the Fund; reinforce application of the Fund’s Rules on Staff Conduct related to conflicts of interest.
- Mandatory in-person ethics induction for new joiners
  - HRD Onboarding included a brief Ethics Office overview in its bi-weekly Onboarding briefing delivered to approximately 463 new Fund employees across 25 sessions during 2025.
  - Ethics Office delivered 12 ethics induction sessions focused on “Ethics and Values” as part of the monthly HRD Onboarding “IMF Essentials” event.
  - Format: hybrid, with two Ethics Office team members present in-person at each session to facilitate engagement.
  - Total engagement in 2025 with new joiners: approximately 463 new Fund employees during a total of 37 sessions.
- Mandatory pre-departure briefings for Resident Representatives (Res Reps)
  - The Ethics Office delivered 13 pre-departure ethics briefings in 2025 for Res Reps prior to the start of assignments.
  - Format: in-person whenever possible or one-on-one Teams meetings when not.
  - Briefings covered role as head of office and Fund representative, affirmative managerial obligations under the Fund’s Standards of Conduct, and new obligations under the Fund’s Anti-Fraud and Anti-Corruption (AFAC) Policy, including proactive steps to prevent and address prohibited activities and failures to avoid, disclose, or mitigate conflicts of interest.
  - The Ethics Office organized an AMA webinar in 2025 on the new AFAC Policy with a Regional Technical Assistance Centers Director as panelist.
- Outreach for Long-Term Experts (LTX)
  - Delivered a total of 14 individual ethics briefings for newly recruited LTXs during onboarding week; mostly in-person, remotely when in-person not feasible.
  - Tailored briefings to role and country environment; emphasis on interactive content.
  - Q1 presentations: Institute for Capacity Development’s LTX retreat attended by 24 LTX; Fiscal Affairs Department’s LTX retreat attended by about 200 Fund employees, including about 100 LTXs; Monetary and Capital Markets Department group call attended by 31 LTX.
  - Particular focus in 2025 LTX briefings: private use of social media and other online engagements by LTXs.
- On-demand in-person ethics training for HQ-based employees
  - Focus topics: (i) parameters and guardrails for political activities and the private use of social media by Fund employees; (ii) obligations of managers and staff regarding reporting alleged misconduct, with emphasis on constructive performance management while avoiding allegations of harassment.
- In-reach sessions for HQ leadership
  - Delivered a total of 18 in-person in-reach sessions (Ethics Office with Communications Department) for senior management teams of all headquarters-based offices and departments on political activities and private social media use.
  - An additional session was held for the A1 to A8 Committee at their request.
  - Ethics Office and HRD hosted a breakfast for participants in the Fund’s 2025 internship program.
  - Targeted sessions on reporting alleged misconduct (Ethics Office with OII) and on constructive performance management (Ethics Advisor with Ombudsperson and HRD) were held for managers in ITD, CSF, and SEC timed ahead of peak performance management cycle periods.
- Ethics training for Executive Board members
  - During Q1 2025 the Ethics Advisor participated in and presented at the Board ethics training for Executive Directors and OED personnel organized by the Office of the General Counsel; this was the third occurrence of the session in the regular ethics awareness program.
- On-demand ethics training outside HQ
  - Virtual presentation at the Quarterly RCDC Directors Meeting (ICD) in Q1 during a case study-based joint session with DRS Heads and the Fund’s Diversity and Inclusion Advisor.
  - In-person training and awareness: AFR Heads of Overseas Offices workshop in Dar es Salaam, APD Field Offices Retreat in Delhi, and MCD Annual Retreat for Heads of Overseas Offices in Riyadh (including local economists and office managers).
  - Ethics training provided for local employees at AFRITAC South, AFRITAC East, SARTAC, and the Fund’s new Regional Office in Riyadh.
  - In-person session for local employees in the Fund’s office in Beijing; virtual session for local employees in the office in Japan delivered jointly with a senior investigator from OII.

### Overview of the Ethics Office’s 2025 outreach efforts
- Ethics Office Open House and 25th anniversary
  - Open House “I ♥ Ethics” marked its 13th consecutive edition and coincided with the Ethics Office’s 25th anniversary.
  - Institutional milestone: the Fund’s Ethics Office was established in early 2000; the Fund’s first Ethics Officer assumed duties on February 7, 2000.
  - Commemoration event: on February 19, 2025 the Fund hosted an interactive panel with internal and external subject matter experts; opening remarks by the Managing Director; panel topics included the Ethics Office’s role in shaping Fund culture, peer institution responses to evolving ethical challenges, and opportunities to promote ethical behavior.
  - Open House format: offered in-person and virtually; three virtual sessions organized to accommodate different time zones and offered in English, French, and Spanish.
- AMA series and internal communications
  - Two AMA sessions hosted in 2025:
    - First session in May (co-organized with OII and LEG) focused on the Fund’s first New AFAC Policy.
    - Second session in December (co-organized with COM, HRD, and SAC) addressed giving, fundraising, and volunteering under the theme Doing Good While Doing the Right Thing during the Fund’s Giving Campaign.
  - AMA series allows non-attributable questions to foster openness and is intended to continue quarterly to reach colleagues globally.
  - Ethics Office expanded outreach via blogs and intranet stories on key ethics topics.
- Engagement with Strategic HR Partners (SHRP) and PRWs
  - Continuous engagement with SHRPs to promote messages on private social media use and managerial obligations to report misconduct; SHRP outreach led to multiple on-demand departmental trainings.
  - Ethics Advisor provided ethics training and awareness raising for new Peers for a Respectful Workplace (PRWs) in Fall 2025 alongside the Ombuds Office, OII, and HRD to prepare PRWs for their advisory role and to guide referrals to appropriate resources.

### Peer learning and institutional engagement
- ENMO participation and Standards of Practice
  - The Ethics Office participates in a network of ethics representatives from over 55 international organizations and IFIs known as ENMO.
  - ENMO adopted the “Standards of Practice” for ethics functions in 2025; the Ethics Advisor actively contributed to preparatory discussions and drafting.
  - ENMO 2025 annual conference hosted by the Asian Infrastructure Development Bank in Beijing: Ethics Advisor led a session on “Recent Ethics Initiatives, Developments, and Lessons Learned” and contributed to a panel on social media and political activities.
- IFI Chapter co-chair role and ongoing meetings
  - In October 2025 the Ethics Advisor became co-chair of the IFI Chapter of ENMO.
  - As IFI Chapter Co-Chair, the Ethics Advisor co-led a quarterly virtual meeting in December 2025 to discuss updates to Standards of Conduct/Code of Ethics in two member organizations; quarterly meetings are expected to continue in 2026.
- MDB symposium engagement and bilateral exchanges
  - Ethics Office engaged peer institutions through MDB compliance functions on institutional conflicts of interest in investments via virtual attendance and presentation at the MDB symposium in October 2025, addressing taxonomy of operational conflicts and comparative systemic approaches.
  - Hosted visits by ethics offices of two regional MDBs: Asian Infrastructure Investment Bank in May 2025 and Central American Bank for Economic Integration in August 2025.
  - Ethics Advisor met with representatives of the European Commission’s Directorate General of Human Resources at their request to discuss the Ethics Office’s experience and good practices for promoting staff integrity and ethical behavior.

*Source: Ethics Office, 2025 Annual Report — SECTION 2: TRAINING AND OUTREACH*

### SECTION 3

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

### Policy Development Workstreams: Review of the IMF Code of Conduct for Fund Staff
- The Ethics Office started a review of the Staff Code of Conduct at the beginning of Q3, with completion expected in early 2026.
- Review activities undertaken:
  - Analysis of existing staff survey data.
  - Stakeholder consultations.
  - External benchmarking amongst relevant comparator IFIs and other international organizations (with assistance of an external consultant).
- Purpose and expected outcome:
  - Proposed updates and enhancements to the Staff Code of Conduct based on findings.
  - An evidence-based roadmap to strengthen clarity, accessibility, and trust in the Staff Code of Conduct and reinforce the Fund’s commitment to a positive and accountable workplace culture.

### Compliance Workstreams: 2025 Financial Disclosure Program (FDP)
- Administration and management:
  - The Ethics Office assumed full administration of the FDP in 2025, having served as contract manager and primary liaison with the Fund’s External Compliance Advisor, KPMG, beginning in 2024.
  - Ethics Office worked closely with KPMG to identify, address, and mitigate any conflict of interest.
- Coverage and participation:
  - The 2025 FDP covered the calendar year 2024 and included a total of 715 individuals as staff filers.
  - The Fund achieved a 100% participation rate.
  - Participating staff included A-15 level in area departments, COM, LEG, MCM, and SPR; all B-level staff; and A-level staff in CSF, FIN, and INV as identified by departments.
  - Participating staff use an electronic system for disclosing personal financial interests and transactions; the system was further enhanced in 2025 with respect to staff separating from the Fund.
  - Public summary statements of interests and activities for certain staff, including the MD and DMDs, have been published online annually since 2023.
- FDP outcomes referred to the Ethics Office by KPMG:
  - 28 submissions were brought to the attention of the Ethics Office for discussion.
  - Findings among those 28 submissions:
    - actual conflict of interest in 3 cases
    - potential conflict of interest in 7 cases
    - apparent conflict of interest in 17 cases
    - no conflict of interest in 1 case
- Forward work:
  - The Ethics Office is preparing a review of the Fund’s Framework on Financial Disclosure and Financial Conflict of Interest as part of its workplan, initiated in 2025 with benchmarking and information gathering, with work to continue to complete the review and make indicated revisions to ensure a strengthened framework in 2026.

### Ethics Office Contributions to the Designated Officer Role and Institutional Conflicts Framework
- Role and tenure:
  - The Ethics Advisor serves as the Financial Conflict of Interest Designated Officer for the Investment Oversight Committee.
  - Appointed by the MD; served in the role since 2014 (initially interim) and in a permanent capacity since 2018.
  - Terms of Reference for the role were approved by Management in 2023.
  - Ethics Office collaborates closely with LEG and FIN in carrying out the role.
- 2025 highlights and forward plans:
  - Full implementation of the 2024 Bright Lines Rule memo to strengthen the institutional conflicts framework.
  - Ethics Office staff co-presented virtually with LEG staff at the MDB Symposium on Conflicts of Interest in October in Manila, Philippines, hosted by the Asian Development Bank, on further development of the institutional conflict of interest framework including the Designated Officer role.
  - Efforts to standardize elements of the Designated Officer role will be undertaken in 2026, in part in anticipation of the quinquennial conflicts of interest review in 2027.

### 2025 Ethical Conduct and Core Values Certification
- Administration:
  - Administered in the third quarter of 2025 by the Ethics Office through the Fund’s Workday portal; this was the fifth time the mandatory Certification was administered through Workday.
- Coverage and compliance:
  - A total of 4,409 Fund staff and long-term contractual employees worldwide were asked to certify.
  - Final overall compliance rate for the 2025 Certification was 99.6%.
  - 21 out of the 25 departments/offices reached 100% compliance.
  - This represents an increase from the 2024 final overall compliance rate of 99.2%.
- Additional activity:
  - The Ethics Office addressed over 30 substantive queries related to the 2025 Certification.

### Ethics Office Participation in Oversight of the IMF Integrity Hotline
- Hotline background and operation:
  - The IMF Integrity Hotline was established in 2008 as a confidential and anonymous reporting service, available online globally and by phone in North America.
  - The Hotline is operated by an independent external service provider through secure web servers and telephone contact centers.
- Oversight Committee composition and reporting:
  - The Ethics Advisor is an ex officio member of the Oversight Committee.
  - The Director of HRD is the Chair; OII serves as Secretariat.
  - Other ex officio members include the Directors of FIN, LEG, and OIA, plus a SAC appointee who is not a current SAC member.
  - The Oversight Committee receives and reviews three reports per year on the Hotline’s operations, with an annual operations report submitted to the MD.
- 2025 engagement:
  - The Ethics Advisor attended three meetings of the IMF Integrity Hotline Oversight Committee in 2025, which facilitated interdepartmental discussion on Hotline reports and broader policy issues.

### Ethics Office Participation in the Domestic Abuse Prevention Program (DAPP)
- Program context:
  - The Fund’s Committee on the Prevention of Domestic Abuse was established in 2012 and includes representatives from the Ethics Office, OII, LEG, Security Services within CSF, HRD, and the Counseling Unit of the Bank/Fund Health and Safety Directorate (HSD).
- 2025 activity and forward plans:
  - The Ethics Office was formally consulted on three DAPP matters in 2025.
  - The Ethics Office supported HRD in streamlining the Committee’s work, updating the Guidelines for Addressing Domestic Abuse, and engaging with the DAPP Manager and DAPP Coordinator at the World Bank.
  - The Ethics Office will remain involved in planned improvements to the Fund’s Domestic Abuse Program in 2026.

### Taking Stock: 25 Years of the IMF Ethics Office — Values into Action
- Milestone and commemoration:
  - The Ethics Office marked its 25-year anniversary in 2025; the first Ethics Advisor took office in February 2000.
  - The anniversary was observed in February 2025 with a panel discussion reflecting on the Ethics Office’s evolution and impact.
- Leadership recognition:
  - The MD underscored the importance of the Ethics Office and highlighted its contributions to good governance and maintaining high ethical standards, emphasizing its role in safeguarding the institution’s reputation for probity, integrity, and impartiality.
- Institutional reflection:
  - Lessons from 25 years emphasize that upholding good governance and ethics is a collective responsibility at personal and institutional levels.
  - Given increased geopolitical and economic uncertainty in 2025, the Ethics function is characterized as needed more than ever within the Fund.

### Ethics Office Contributions to the Fund’s Work on Artificial Intelligence (AI)
- Role and engagement:
  - In 2025, the Ethics Office proactively contributed to the Fund’s internal work on AI to ensure ethical integration into institutional operations and decision-making.
  - The Ethics Office actively contributed to the 2025 updates to the IMF Responsible AI Use Guidelines.
  - Since January 2025, the Ethics Advisor has served as a member of the Fund’s AI Coordinating Committee.

### Preparations for Mandatory Ethics Training (MET) Relaunch
- Prior MET cycle:
  - The Ethics Office completed the fourth cycle of Fund-wide, in-person MET at the end of 2024.
  - Over the course of the rollout, 97 sessions were delivered, reaching a total of 4,036 staff members and long-term contractual employees.
- 2025 review and 2026 relaunch:
  - In 2025, the Ethics Office conducted a comprehensive review of the MET program using internal qualitative and quantitative data, including participant feedback and post-training survey responses.
  - An external benchmarking assessment reviewed mandatory ethics training practices across leading IFIs, MDBs, and other international organizations.
  - The next MET cycle is scheduled to resume in early 2026, aiming to use data-driven analysis, behavioral insights, and tailored content and delivery to strengthen ethics awareness and practical application among Fund staff and long-term contractual employees.

### Looking Ahead: Policy Initiative to Update the Financial Disclosure Framework
- The Ethics Office included a review of the Fund’s Framework on Financial Disclosure and Financial Conflict of Interest in its 2026 workplan.
- Following a benchmarking exercise undertaken in 2025, work will continue in 2026 to make appropriate revisions and ensure a further enhanced and refreshed framework is in place in 2026.

### The Fund’s Core Values (as stated)
- EXCELLENCE: We strive for excellence in our work and in all our interactions with our member countries and all stakeholders of the Fund. We work together to the highest professional standards for the common public good of our global membership.
- HONESTY: We tell the truth. We are straightforward in our actions and honest in our relationships. When we say we will do something, we follow through and honor our commitments.
- IMPARTIALITY: We are objective, neutral, and impartial in providing advice and in discharging our professional obligations. Our professional judgment is not influenced by partisan politics, outside authorities or personal bias. We are responsible to our members and earn their trust and confidence every day.
- INCLUSION: We value diversity. We build diverse professional networks and teams fostering an engaging and inclusive environment that values individual uniqueness. We treat people as we would like to be treated. We respect each other and do not tolerate discrimination.
- INTEGRITY: We do what is right for our members, our communities, the Fund, and each other. We make hard decisions and tough choices. We do not compromise our values.
- RESPECT: We treat our colleagues, whether supervisors, peers, or subordinates, with courtesy and respect, without harassment, or physical or verbal abuse.

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_Source: https://www.imf.org/-/media/files/about/ethics/annual-report/eoar2025.pdf_