## ppea2022061 ## Source details **Canonical URL:** [ppea2022061](https://www.imf.org/-/media/files/publications/pp/2022/english/ppea2022061.pdf) ## Other formats - [Markdown version](/-/media/files/publications/pp/2022/english/ppea2022061.pdf.md) - [Structured JSON version](/-/media/files/publications/pp/2022/english/ppea2022061.pdf.json) --- ### EXECUTIVE SUMMARY — Overview and context and Key findings - Ensuring the highest standards of institutional governance and data and analytical integrity is paramount to the IMF’s mandate. - Executive Board concluded review of matters raised in the investigation of the 2018 World Bank’s Doing Business report in October 2021 and launched the Institutional Safeguards Review; an external independent panel of experts assessed the Fund’s internal dispute resolution system (DRS). - Institutional Safeguards Review completed and discussed by the Executive Board on June 30, 2022. - This Implementation Plan (IP) sets out timelines, responsibilities, required staff and gross budget resources, monitoring arrangements, and explanations where recommendations may not be feasible or practical. - Document date on the cover: November 30, 2022. - Key findings: - Fund generally has robust mechanisms to ensure a high standard of institutional governance and analytical integrity. - Fund’s DRS is “comparable to the practices and procedures in other benchmarked international organizations” and provides “multiple formal and informal mechanisms” for employees to express workplace concerns. - Identified areas for strengthening: - data and analytical integrity frameworks; and - smooth and effective functioning of the Fund’s internal dispute resolution system. ### IMPLEMENTATION PLAN — Organizing themes and representative actions - Four mutually reinforcing themes: - Data and Analytical Integrity - Leadership: Tone from the Top - Building Trust and Increasing Transparency in the DRS and Ethics and Integrity Offices - Strengthening the DRS and Related Processes - Representative actions (selected): - Data and Analytical Integrity: - Clarify staff’s engagement with Offices of Executive Directors (OED). - Clarify Management’s role in clearance of staff papers. - Ensure evenhanded coverage of emerging areas in surveillance. - Increase transparency and documentation of internal review process. - Leadership: Tone from the Top: - Review the ethical framework applicable to the Board and Management; introduce ethics training for all Board members and their staff. - Ensure greater transparency into the work of the Ethics Committee. - Publication of Financial Disclosures of Management (summaries for DMDs targeted in latter half of 2023 and annually thereafter). - Grant access of OED employees to informal services of the DRS. - Clarify role of Management in Internal Audit work plans. - Building Trust and Increasing Transparency in the DRS and Ethics and Integrity Offices: - Policy initiatives addressing retaliation; development of a Whistleblower Policy. - Increase accessibility to the DRS, transparency and access to information. - Workstreams to reduce litigiousness and formality of the Grievance Committee process. - Provide legal assistance to staff (Staff Legal Counsel proposal). - Streamline the administrative review process; explore DRS access for contractual employees. - Strengthening the DRS and Processes: - Address delays and inefficiencies in the DRS. - Review autonomy, resourcing, and staffing of DRS offices. - Identify measures to incentivize and prioritize time required by participants in the Grievance Committee system. ### FOLLOW-UP, VALIDATION, MONITORING - Overall implementation will be subject to follow-up and validation by the Office of Internal Audit (OIA). - Approach consistent with process for Board-endorsed IEO recommendations through OIA’s Periodic Monitoring Reports (PMRs). - Impact monitoring: - Regular staff engagement surveys, including the Staff Engagement Survey (SES) — first comprehensive staff survey since 2017 and following Covid-19 — to set baseline (CY22 Q4, CY23 Q1). - Annual pulse surveys to follow for two years. - OIA milestones: - Interim implementation update by staff to the Board planned for end-CY2023. - OIA progress report planned for issuance in the first half of CY2024 to independently validate completion of actions and report on in-train workstreams. - Sustaining monitoring will require ongoing commitment and senior-level involvement. ### A. Data and Analytical Integrity — Findings, Actions, Timing - Finding: Strong frameworks exist but can be enhanced to protect staff analysis from undue pressure. - WGDAI observations: Engagement with Management and OEDs broadly works well but can at times be subject to undue pressure. - Actions under way: - Draft note operationalizing shared principles for OEDs and staff guidance, including clear definition of “undue influence.” - Explore mechanisms for staff to address or resolve instances of undue influence (in consultation with DRS and SG offices). - Draft guidance clarifying Management’s role in clearance of staff papers, including requirements for memoranda to Management and documentation of Management decisions. - Prepare guidance for evenhanded coverage of emerging topics in surveillance, guided by evenhandedness framework and Board-approved strategies on climate and gender; Board briefings planned. - Strengthen transparency and documentation of internal review process (require authoring departments to provide accounts of how main comments were addressed; expand use of eReview until IDW successor rolled out; assess adaptation after IDW implementation). - Implementation timing: Most actions expected by CY2023 Q1/Q2. - Responsible: SPR, LEG, SEC in close consultation with Board SG and OIA where applicable. ### B. Leadership: Tone from the Top — Findings, Actions, Timing - Objective: Strengthen ethical framework for Board and Management; enhance transparency; expand dispute resolution mechanisms for OED employees. - Key actions and milestones: - Full review of the Board Code of Conduct and ethical framework for the Managing Director to be conducted in the first half of CY2023; proposed changes presented later that year. - Board members and all OED employees to undertake annual ethics training; first overview provided November 2022; detailed annual training planned for CY23 Q1. - Ethics Committee to publish summary statements on its activities at the end of each two-year term; first such statement published for all staff on November 8, 2022. - Management supports publication of summaries of financial interests for DMDs: summaries to be published at end of next annual financial disclosure process in the latter half of 2023, and annually thereafter; Management’s views to be conveyed to Ethics Committee for MD’s framework. - CAM to operationalize policy changes granting OED employees access to informal DRS services (Ombudsperson and Mediator): staff proposals at start of CY2023, completion targeted by Q2 2023; broader formal access to be considered after experience gained. - OIA Program of Work oversight: propose EAC approval of OIA’s Program of Work with documented process for Management’s suggested modifications; would require amendment to OIA and EAC Charters. - Regular engagement commitments: at least once a year a joint meeting between Management and DRS and Ethics and Integrity Offices; annual Board briefing; informal engagements (retreats/luncheons). - Timing highlights: CY23 Q1/Q2 and Q2/Q3 for code and ethics reviews; April 2023 target for CAM consideration on OED informal DRS access. ### C. Building Trust and Increasing Transparency in DRS, Ethics, and Integrity Offices — Policies and Processes - Retaliation and protections: - Proactive use of interim protective measures for complainants or witnesses to be included in next Staff Handbook update and actively communicated. - Development of standalone Whistleblower Policy: Task Team (ETO, HRD, LEG, OII and SAC) to draft policy for Management decision by end-CY2023; Team will assess implications of extending time limit for access to special Independent Review for retaliation claims from six months to three years. - Recommendation to shift burden of proof to alleged wrongdoer in retaliation cases will not be taken forward; Staff Handbook to clarify consequences and referral for inclusion in individual performance reviews where failures to document reasons for adverse actions occur. - Add provision to Retaliation Policy Section 4.4 requiring OII, when IR determines retaliation has occurred, to advise on whether OII will request authorization to conduct an investigation into individual misconduct per GAO 11, Chapter 11.02, Section 4.3. - Accessibility and process improvements: - HRD to introduce in Q1 CY2023 a standardized online Administrative Review Intake Form (including desired action) and an Exit Questionnaire to aid case tracking and early resolution. - Grievance Committee reform workstream (Grievance Chair, HRD, LEG, SAC) to review comparator practices and propose measures to reduce formality and litigiousness, incentivize peer reviewers and witnesses, and improve scheduling and efficiency; proposals due end-2023 / Q4 CY2023. - Publication and transparency: - Grievance Committee to complete publication of redacted copies of its recommendations (since 2018) to its intranet site by end-CY2022. - Grievance Committee Annual Report for 2022 to be published in CY2023. - HRD publishing at end-CY2022 its Annual Report on Administrative Reviews for 2019, 2020, and 2021; 2022 Annual Report to be published in CY2023 and annually thereafter. - OII to augment Annual Reports with summaries of cases and outcomes, including corrective measures in retaliation cases, balanced for confidentiality. - Real-time case tracking: - Task Team (DRS Offices, LEG, HRD, ITD) to research solutions and prepare proposal for Management decision; proposal and costing to be developed for FY25 capital budget input. ### Staff Legal Counsel (SLC), Administrative Review, Contractual Employees — Scope, Timelines, Resources - Staff Legal Counsel (SLC): - Task Team (Grievance Committee Chair, HRD, LEG, SAC) to develop proposal addressing SLC scope, terms and conditions, and incentives; proposal completion for Management decision: Q4 CY2023. - Related resource implications to be assessed as part of the regular budget process for FY25. - Potential follow-on: Tool-Kit for Self-Represented employees could be prepared by SLC. - Administrative Review process: - Maintain mandatory first step of Administrative Review for benefits disputes; consider making first step optional in other cases. - Enforced and shorter timelines will require additional resourcing. - Task Team (HRD, LEG, SAC) to prepare proposal for Management decision by Q3-4 CY2024. - Contractual employees: - Contractual employees have access to final and binding arbitration and informal DRS mechanisms; arbitration available since 1993 with amendments. - Contractual employees fall under a different legal regime; access to formal DRS mechanisms raises complex legal issues. - Task Team (HRD, LEG, SAC, Ombudsperson) to develop proposals by Q4 CY2024. ### DRS Employment Framework, Workforce Planning, and Office Head Appointments - Employment framework modifications: - Recommendation to revise DRS employment framework supported with modification: DRS, Ethics and Integrity offices must conform with the Fund’s Categories of Employment (COE) and competitive selection requirements; allowing current employees “to elect conversion” is not supported. - Workforce planning and resourcing: - HRD to formalize workforce plans for DRS offices within next six months for implementation beginning in FY24. - FY23 budget provided five structural staff positions and an overall 30 percent increase in DRS resourcing. - Heads of DRS offices expressed concern about morale due to approach and budgetary constraints. - Office Head appointment category: - Use of fixed-term staff appointments for four DRS Office Head positions (ETO, MDT, OII, OMB) would require amendment to the 2014 COE Board Paper (EBAP/14/89). - Task Team (HRD, LEG, SAC) to prepare a draft Board paper and a fully costed proposal for Management and Board decision in Q3 CY2023. - Estimated cost noted: approximately $110,000 per position (for Heads of offices) in the Annex. ### Workstreams, Prioritization, Governance, and Selected Timelines - Workstream approach: Senior lead and project manager appointed for each workstream; time-bound workstreams where further consultation required. - Prioritization criteria: impact/importance, cost effectiveness, ease of implementation, sequencing and interdependencies. - Selected workstreams and decision timeframes: - Board Ethics Committee – Review of the Board Code of Conduct: Q2-3 2023. - Task team on culture change (HRD, COM): Q4 2023. - Task Team to develop proposals to improve the Grievance Committee process and provide Staff Legal Counsel (Grievance Committee Chair, HRD, LEG and SAC): Q4 2023. - HRD proposal to restructure HRD Employment Practices and handling of employee relations matters: Q4 2023. - Task Team to develop a Whistleblower Policy and propose amendments to misconduct investigation procedures (ETO, HRD, LEG, OII and SAC): Q3-4 2023. - Task Team to consider employment framework for DRS Offices Heads: Q3 2023. - Task Team to explore IT options for Real-Time Case Tracker (DRS, HRD, LEG, ITD): Q3 2024. - Task Team to consider reforms to Administrative Review process (HRD, LEG, SAC): Q3-Q4 2024. - Task Team to consider dispute resolution procedures for contractual employees (LEG, HRD, SAC, OMB): Q4 2024. ### Resource Implications and Budgeting - Resourcing approach: - IP-related actions resourced through annual budget process. - Initial work resourced by absorption in existing departmental envelopes via re-prioritization or through temporary working budget adjustments. - Budget implications incorporated in FY24 and future budget cycles; re-prioritization may affect timelines and deliverables of existing projects. - Main areas with recurring resource implications: - (a) changes in scale and mix of personnel within DRS offices and HRD’s administrative review and employee relations function; - (b) proposals for legal representation for staff; - (c) targeted culture change efforts and their phasing; - (d) implementation of a real-time case tracker (with related capital spending). - Specific cost notes: - FY23 allocated five structural staff positions and a 30 percent increase in DRS resourcing. - Draft Board paper for Heads of offices to include a fully costed proposal (approximately $110,000 per position referenced). ### Ensuring Accountability and Durable Culture Change - Departmental assignments from the IP to be reflected in accountability frameworks and the budget process. - Independent follow-up and validation by OIA. - Interim implementation update: staff to Board end-CY2023. - OIA progress report: first half CY2024 to validate completion and report on in-train workstreams. - Culture-change initiatives: - COM outreach events and intranet updates about DRS services. - DIO to interact with Departments’ staff groups, conduct stock-take of programs, and undertake staff-level focus groups to identify reasons for lack of trust and fear of retaliation; DIO proposal on strengthening programs due Q4 CY2023. - Staff surveys: - SES to set baseline (CY22 Q4, CY23 Q1); annual pulse surveys thereafter. ### Annex I — Selected Recommendation Matrix Highlights (DAI, EP categories) - DAI timelines and responsibilities: - DAI 1 — Clarify OED engagement with staff: Timeline CY2023 Q1/Q2; Responsible: SPR, LEG, and SEC. - DAI 2 — Clarify Management role in clearance: Timeline CY2023 Q1; Responsible: SPR, LEG, and OMD advisors. - DAI 3 — Evenhanded coverage guidance: Timeline CY2023 Q1; Responsible: SPR. - DAI 4 — Strengthen transparency of internal review and assess IDW adaptation: (a) CY2023 Q1; (b) commence after IDW rollout; Responsible: SPR, OIA. - EP highlights: - EP1 — Review Board Code of Conduct and MD framework: Timeline CY23 Q2/3; Responsible: Ethics Committee, LEG, Ethics Advisor. - EP2 — Publish DMDs financial summary disclosures: Timeline CY23 – Q1/2 for decisions; Responsible: Ethics Office, OMD, Board Ethics Committee, LEG. - EP3 — OED access to informal DRS: Timeline CY23 Q2 (CAM consideration in CY2023 Q1; target April 2023); Responsible: CAM, LEG, SEC, OMB, MDT. - EP8 — Retaliation policy revisions and supervisory responsibilities: Timing CY23 Q1/2; Responsible: OII in consultation with HRD, LEG, ETO and DRS. - EP10 — DRS consolidation, Tool-Kit, and real-time tracker: Tool-Kit timeline CY24 Q2/3; real-time tracker proposal timeline CY24 Q3; Responsible: HRD, LEG, SAC, ITD, DRS. - EP11 — DRS employment framework and workforce planning: Timeline CY23 Q2 onwards; Task Team to prepare draft Board paper CY23 Q3; Responsible: HRD. - EP12/EP13 — OII terms of reference and investigative centralization: Timeline CY23 Q1/2; Responsible: OII, HRD, LEG. - EP17/EP39/EP35/EP36/EP37/EP38/EP40 — Grievance Committee and DRS process reforms: Key deliverables due CY23 Q4 and CY24 Q3/4; Responsible parties include Grievance Committee Chair, LEG, HRD, SAC, OII, OBP. - EP30 — Culture Change Program analysis: Analysis period CY22 Q4 to CY23 Q4; Responsible: HRD. *Implementation Plan in Response to Recommendations of the 2022 Institutional Safeguards Review, November 30, 2022.* ### EXECUTIVE SUMMARY ### EXECUTIVE SUMMARY ### Overview and context - Ensuring the highest standards of institutional governance and data and analytical integrity is paramount to the International Monetary Fund’s (IMF) ability to deliver on its mandate. - In concluding its review of matters raised in the investigation of the 2018 World Bank’s Doing Business report in October 2021, the Executive Board noted confidence in the impartiality and analytical excellence of IMF staff and in the IMF’s complaint, dissent, and accountability channels, while considering “possible additional steps to ensure the strength of institutional safeguards.” - The Board launched a comprehensive Institutional Safeguards Review in collaboration with Fund Management and two staff working groups; an external independent panel of experts was appointed to assess the Fund’s internal dispute resolution system (DRS). - The Institutional Safeguards Review was completed and discussed by the Executive Board on June 30, 2022. - This Implementation Plan (IP) sets out timelines, responsibilities, required staff and gross budget resources, monitoring arrangements, and explanations where recommendations may not be feasible or practical. The IP reflects input from all stakeholders and a consensus approach by the Board Steering Group (SG) and Management. - Document date on the cover: November 30, 2022. ### Key findings of the Review - The Review found that the Fund generally has robust mechanisms to ensure a high standard of institutional governance and analytical integrity. - The Review found that the Fund’s dispute resolution system (DRS) is “comparable to the practices and procedures in other benchmarked international organizations” and provides “multiple formal and informal mechanisms” for employees to express workplace concerns. - The Review identified areas where: - data and analytical integrity frameworks could be further bolstered; and - the smooth and effective functioning of the Fund’s internal dispute resolution system could be strengthened. ### Implementation Plan: organizing themes and principal actions - The IP groups actions into four mutually reinforcing themes: - Data and Analytical Integrity - Leadership: Tone from the Top - Building Trust and Increasing Transparency in the DRS and Ethics and Integrity Offices - Strengthening the DRS and Related Processes - Representative actions under each theme: - Data and Analytical Integrity - Clarify staff’s engagement with Offices of Executive Directors (OED). - Clarify the role of Management in the clearance of staff papers. - Ensure evenhanded coverage of emerging areas in surveillance. - Increase transparency and documentation of the internal review process. - Leadership: Tone from the Top - Review the ethical framework applicable to the Board and Management. - Introduce ethics training for all Board members and their staff. - Ensure greater transparency into the work of the Ethics Committee. - Publication of Financial Disclosures of Management. - Grant access of OED employees to the Informal services of the DRS. - Clarify the role of Management in Internal Audit work plans. - Clarify the role of Board and Management in supporting a positive change in organizational culture. - Building Trust and Increasing Transparency of the DRS and Ethics and Integrity Offices - Policy initiatives addressing retaliation. - Development of a Whistleblower Policy. - Increase accessibility to the DRS, and transparency and access to information. - Workstreams to reduce litigiousness and formality of the Grievance Committee process. - Provide legal assistance to staff. - Streamline the administrative review process. - Explore granting contractual employees access to the DRS. - Strengthening the DRS and Processes - Address delays and inefficiencies in the DRS. - Review the autonomy, resourcing, and staffing of DRS offices. - Identify measures to incentivize and prioritize the time required by participants in the Grievance Committee system (peer reviewers, witnesses and others) to process disputes more efficiently. ### Progress, timelines, and monitoring - A large majority of recommendations from the Review are supported. - The Board, Management, and staff have made considerable progress on near-term actions set out in the June 30, 2022 Joint Statement. - The IP envisages further substantial progress in CY2023 and comprehensive actions into CY2024. - For recommendations requiring further consultation, time-bound workstreams are established to determine the path forward against defined timelines; the Workstreams Matrix (Table 1) and Annex I (Matrix of Recommendation and Implementation Plan) set out composition and timelines. - Overall implementation will be subject to strong follow-up and validation by the Office of Internal Audit (OIA). - Sustaining and monitoring progress will require ongoing commitment, including regular staff engagement surveys and senior-level involvement. ### Categorization of recommendations and implementation approach - Recommendations are categorized as: - Support—to be implemented: supported recommendations with an IP; implementation can largely proceed within existing resources, with additional gross resources reviewed in the forthcoming budgetary cycle where needed. - Support—with modification: support for the underlying intention but with an alternative resolution proposed. - Requires further consultations: broad in-principle support but additional discussion needed to reach consensus; time-bound workstreams will address these. - Do not take forward: recommendations not implemented because they do not fit IMF operations or existing frameworks already address the underlying aim. - Workstreams will be led by a senior staff member with a project manager to propose a way forward to Management and, where relevant, the Executive Board, against defined timelines. ### Governance, task force, and institutional commitments - The IP was prepared by a Task Force led by David Marston, receiving substantive inputs from staff across HRD, LEG, COM, SPR, OIA, ORM, SEC, ATB, ETO, GRC, MDT, OII, OMB, OII, OMB and SAC representatives. - The Task Force work was supervised by Ceyla Pazarbasioglu, Catriona Purfield, and Rhoda Weeks-Brown, and received advice from an Advisory Committee comprised of the Directors of AFR, COM, EUR, HRD, LEG, OBP, SEC, and SPR as well as SAC representatives. - The Board Steering Group was led by Ms. Riach (OEDUK) in coordination with Management. - The Board and Management emphasize that realizing durable institutional and cultural change is a long-term agenda and some actions will take longer than others. *Implementation Plan in Response to Recommendations of the 2022 Institutional Safeguards Review, November 30, 2022.* ### 12. Overall implementation will be subject to follow-up and validation by the Office of ### 12. Overall implementation will be subject to follow-up and validation by the Office of ### Follow-up, validation, and monitoring - Overall implementation will be subject to follow-up and validation by the Office of Internal Audit (OIA). - Approach consistent with process for Board-endorsed IEO recommendations through OIA’s Periodic Monitoring Reports (PMRs). - Impact of IP’s actions to strengthen Institutional Safeguards and foster a more open culture will be monitored through regular staff engagement surveys. ### Recommendations and implementation plan (overview) - All recommendations of the Review, including near-term action items in the Joint Statement, are considered in the IP. - Annex 1 sets out a matrix of actions responding to each supported recommendation, with timelines and responsible stakeholders. - Description that follows explains how the IP responds to thematic areas. ### A. Data and Analytical Integrity — findings and actions - Finding: Strong frameworks and processes exist, but improvements can enhance protection of staff analysis from undue pressure. - WGDAI identified that engagement with Management and Offices of Executive Directors (OEDs) broadly works well but can at times be subject to undue pressure. - Actions underway: - Drafting a note operationalizing shared principles for OEDs and detailing staff guidance, including a clear definition of “undue influence.” - Exploring mechanisms for staff to address or resolve instances of undue influence, in consultation with DRS and SG offices (see para. 24). - Drafting guidance to clarify Management’s role in clearance of staff papers, including requirements for memoranda to Management and documentation of Management decisions. - Preparing practical guidance for evenhanded coverage of emerging topics in surveillance, guided by the Fund’s evenhandedness framework and Board-approved strategies on climate and gender; Board briefings planned. - Strengthening transparency and documentation of the internal review process: - Guidance requiring authoring departments to provide reviewing departments and Management with an account of how main comments were addressed. - Expanding scope of documents using the eReview system until IDW successor is rolled out. - Following IDW implementation, an assessment will occur on how the internal review process adapted to the new platform. - Implementation timing: Most actions expected to be implemented by CY2023 Q1/Q2 (see Matrix). - Communication: Management and the Executive Board will undertake communication events with staff to support implementation. ### B. Leadership: Tone from the Top — findings and actions - Objective: Strengthen ethical framework for the Board and Management, support transparency, and enhance dispute resolution mechanisms for OED employees. - Actions and milestones: - Executive Board agreed to a full review of the Code of Conduct for Members of the Executive Board and the ethical framework applicable to the Managing Director; review to be conducted in the first half of CY2023, with proposed changes presented to the Executive Board later that year. - Board Ethics Committee proposals prepared; Board members and all OED employees to undertake annual ethics training. - Executive Board will share summary statements on the Ethics Committee’s activities at the end of each two-year term; first such statement published for all staff on November 8, 2022. - Ethics Committee decided not to recommend changing its composition to include a majority of external members based on benchmarking of eight comparators. - Management supports publication of summaries of financial interests for DMDs: - Framework to apply to DMDs with summaries published at end of next annual financial disclosure process in the latter half of 2023, and annually thereafter. - Management’s views to be conveyed to the Ethics Committee for the MD’s framework. - CAM to operationalize policy changes granting OED employees access to informal DRS services (Mediator and Ombudsperson): - Staff to submit proposals at the start of CY2023, with completion targeted by Q2 2023. - After experience gained, consideration will be given to broader access to the formal dispute resolution system. - OIA Program of Work oversight: - Proposal to have External Audit Committee (EAC) approve OIA’s Program of Work while preserving Management’s ability to suggest modifications; OIA Director to communicate suggested modifications to the EAC and document dispositions. - Change would require amendment to OIA and EAC Charters. - Regular engagement commitments: - At least once a year a joint meeting between Management and DRS and Ethics and Integrity Offices to discuss annual reports. - An annual Board briefing with Management and relevant DRS and Ethics and Integrity Heads. - Informal engagements (e.g., retreat or luncheon) to foster exchange and awareness of DRS activities. - Communications products and events planned to keep staff informed of IP implementation. ### C. Building trust in and increasing transparency in the DRS, Ethics, and Integrity Offices — findings and actions - Finding: Need to foster staff trust in DRS and Ethics and Integrity Offices and reassure users they are protected against adverse action. - Policy changes: - Proactive use of interim protective measures for complainants or witnesses of alleged retaliation, including alleged undue influence; to be included in next Staff Handbook update and actively communicated to staff. - Development of a standalone Whistleblower Policy to confirm protection from adverse action: - Task Team of ETO, HRD, LEG, OII and SAC to draft policy for Management decision by end-CY2023. - Team will assess implications of extending time limit for access to special Independent Review for retaliation claims from six months to three years. - Recommendation to shift burden of proof to alleged wrongdoer in retaliation cases will not be taken forward; benchmarking and due process considerations cited. - Staff Handbook to be revised to clarify that if an Independent Review finds retaliatory action, consideration will be given to initiating a misconduct investigation; failures to document reasons for adverse actions would be referred for inclusion in individual performance reviews. - Rules to establish protocol for consideration of reinstatement recommendations/orders by Grievance Committee or Administrative Tribunal: - Task Team of HRD, LEG and SAC to propose a new Staff Handbook rule setting out a formal decision-making protocol for reinstatement consideration. - Enhancing accessibility of the DRS: - HRD to introduce in Q1 CY2023 a standardized online Administrative Review Intake Form (including a section on desired action) and an Exit Questionnaire to aid case tracking and early resolution. - Grievance Committee process reform: - Recognition that the Grievance Committee process has become more adversarial and time-consuming over its 40 years. - SAC does not support turning the Grievance Committee into a peer review system and calls for reformed discovery policy; views diverge. - Task Team (Grievance Committee Chair, HRD, LEG, SAC representatives) to: - Review comparator organizations’ practices and determine whether design changes are recommended. - Develop proposals to reduce formality and litigiousness and re-focus the Committee on essential fact-finding. - Develop proposals to incentivize and prioritize time commitments of peer reviewers, witnesses, and others to improve scheduling and efficiency. - Submit proposals to Management by end-2023. *Source: IMPLEMENTATION PLAN IN RESPONSE TO RECOMMENDATIONS OF THE 2022 INSTITUTIONAL SAFEGUARDS REVIEW (extract).* ### 33. Notwithstanding broad support in principle for providing appropriate legal assistance ### 33. Notwithstanding broad support in principle for providing appropriate legal assistance to staff at the Fund’s expense, a variety of issues will need to be considered in operationalizing the proposal. ### Staff Legal Counsel (SLC) — scope, timing, and resources - A Task Team described in para. 32 will develop a proposal to address: - the intended nature and scope of the Staff Legal Counsel (SLC’s) functions; and - the terms and conditions of the SLC’s appointment, ensuring appropriate incentives for prudent use and costs. - The SLC proposal will be informed by work to improve the Grievance Committee processes. - Timeline and budgeting: - Proposal completion for Management decision: Q4 CY2023. - Related resource implications to be assessed as part of the regular budget process for FY25. - Follow-on deliverable: - Recommendation to develop a Tool-Kit for Self-Represented employees could be prepared by the SLC as a useful resource for staff. ### Administrative Review process — streamlining and timelines - Immediate/near-term process changes under consideration: - Maintain mandatory first step of Administrative Review for benefits disputes (review by the Division Chief of HRD Total Rewards). - Consider making the first step of Administrative Review optional in other cases. - Enforced and shorter timelines for administrative review cases will require additional resourcing. - Governance: - A Task Team comprising HRD, LEG, and SAC will prepare a proposal for Management decision by Q3-4 CY2024. ### Contractual employees — existing regimes and potential reforms - Current access and history: - Contractual employees have access to final and binding arbitration and informal DRS mechanisms, including recourse to the Ombudsperson and the Mediator. - An arbitration process has been available to contractual employees since 1993, amended to allow the application of the same procedural safeguards afforded to staff under the grievance process. - Policy challenge: - Contractual employees fall under a different legal regime than staff, raising difficult issues for access to formal DRS mechanisms. - Next steps: - A Task Team of HRD, LEG and SAC, including the Ombudsperson, will develop proposals for any amendments to the dispute resolution procedures applicable to contractual employees by Q4 CY2024. ### Improving transparency and access to information - Reporting and publication actions and timelines: - Grievance Committee will complete publication of redacted copies of its recommendations (since 2018) to its intranet site by end-CY2022. - Grievance Committee Annual Report for 2022 will be published in CY2023. - HRD is publishing at end-CY2022 its Annual Report on Administrative Reviews for 2019, 2020, and 2021. - The 2022 Annual Report on Administrative Reviews will be published in CY2023 and annually thereafter. - Case status and tracking: - Immediate action: all offices and bodies to provide regular status and progress updates; employees may request an update on case progress at any time (generally by email). - A real-time case tracking platform is identified as valuable. - A Task Team comprising the DRS Offices, LEG, HRD, and ITD will research available solutions and prepare a proposal for Management decision. - The proposal and costing are to be developed for input to the FY25 capital budget. - Awareness and protections: - HRD has added standard information about protections under the Retaliation Policy in findings to staff using the Administrative Review process. - OII will augment its Annual Reports to provide summaries of cases addressed and their outcomes, including corrective measures taken in retaliation cases, balanced for confidentiality. ### Oversight, employment framework, and DRS staffing - Employment framework modifications: - Recommendation to revise the DRS employment framework approved in 2021 is supported with a modification: DRS, Ethics and Integrity offices must conform with the Fund’s Categories of Employment (COE) and competitive selection requirements; allowing current employees “to elect conversion” is not supported. - Workforce planning and resourcing: - HRD will formalize workforce plans for DRS offices to form the basis for budget discussions within the next six months for implementation beginning in FY24. - This builds on: - five structural staff positions; and - an overall 30 percent increase in DRS resourcing allocated to the offices in the FY23 budget process. - Heads of the DRS Ethics and Integrity Offices have expressed disappointment and concern about morale due to approach and budgetary constraints. - Office Head appointment category: - Use of fixed-term staff appointments for four DRS Office Head positions (ETO, MDT, OII, OMB) would require an amendment to the 2014 Categories of Employment Board Paper (EBAP/14/89). - A Task Team comprising HRD, LEG and SAC (in consultation with the DRS) will prepare a draft Board paper and a fully costed proposal for Management and Board decision in Q3 CY2023. ### Structure of employee-relations teams and HRD proposals - HRD actions: - HRD will determine appropriate structure of teams handling employee relations (including HRD Total Rewards Division, HRD Employment Practices, and Strategic HR Partner (SHRPs)). - HRD will prepare a proposal for Management decision by Q3 CY2023 on possible changes to staffing structure for discussion as part of HRD’s budget proposal for FY25. - Proposal will include standardized benchmarking of employee relations unit/team structures in other public and private sector organizations. - Objective: ensure early informal dispute resolution and timely formal Administrative Reviews are adequately staffed by suitably qualified and experienced personnel. ### Workstreams, prioritization, and governance - Workstream approach: - IP envisages workstreams for ongoing consultations to reach consensus or better define responses. - Prioritization criteria: impact and importance for staff/institution, cost effectiveness, ease of implementation, sequencing and interdependencies. - For each workstream, Management will appoint a senior lead and a project manager to coordinate, with view to tabling proposals to Management and, where relevant, the Executive Board, against defined timelines. - Table of selected workstreams and decision timeframes (as set out in the text): - Board Ethics Committee – Review of the Board Code of Conduct: Q2-3 2023. - Task team on culture change (HRD, COM): Q4 2023. - Task Team to develop proposals to improve the Grievance Committee process and provide Staff Legal Counsel (Grievance Committee Chair, HRD, LEG and SAC): Q4 2023. - HRD proposal to restructure HRD Employment Practices and handling of employee relations matters: Q4 2023. - Task Team to develop a Whistleblower Policy and propose amendments to misconduct investigation procedures (ETO, HRD, LEG, OII and SAC): Q3-4 2023. - Task Team to consider employment framework for DRS Offices Heads: Q3 2023 (for office Heads). - Task Team to explore IT options for Real-Time Case Tracker (DRS, HRD, LEG, ITD): Q3 2024. - Task Team to consider reforms to Administrative Review process (HRD, LEG, SAC): Q3-Q4 2024. - Task Team to consider dispute resolution procedures for contractual employees (LEG, HRD, SAC, OMB): Q4 2024. ### Resource implications and budgeting - Resourcing approach: - Resourcing of IP-related actions will be incorporated into the annual budget process. - Initial work resourced by absorption in existing departmental envelopes via re-prioritization or through temporary working budget adjustments under regular budget procedures. - Budget implications of IP-related proposals will be incorporated in the context of the FY24 and future budget cycles, consistent with sequenced follow-up timelines, and accommodated within the overall envelope approved by the Board through re-prioritization. - Re-prioritization will have implications on timelines and deliverables of existing projects and work programs of affected Departments; trade-offs to be discussed with Management in Accountability Framework and Board Work Program contexts. - Main areas with recurring resource implications (potential additional resources required): - (a) changes in the scale and mix of personnel within DRS offices and HRD’s administrative review and employee relations function; - (b) proposals for legal representation for staff; - (c) targeted culture change efforts and their phasing; - (d) implementation of a real-time case tracker (with related tools potentially affecting capital spending). ### Ensuring accountability and durable culture change - Independent validation and reporting: - Departmental assignments from the IP will be reflected in respective accountability frameworks and the budget process. - Independent follow-up and validation by the Office of Internal Audit (OIA). - An interim implementation update by staff to the Board is planned for end-CY2023. - An OIA progress report, planned for issuance in the first half of CY2024, will independently validate completion of actions and report on in-train workstreams and actions. - Subsequent implementation updates could be consolidated under OIA’s annual progress reports and leverage OIA audits, staff engagement surveys, pulse surveys to assess outcomes. - Culture-change initiatives: - Comprehensive actions under the IP aim to underpin culture change through policy, process and accountability changes, accompanied by initiatives to raise awareness of Ethics and Integrity Offices and the Retaliation Policy. - COM is undertaking outreach events and enhancing intranet information about DRS services. - DIO will leverage ongoing programs, interact with Departments’ staff groups, support departmental action plans, and undertake a stock-take of programs, including managerial competencies, to identify strengthening opportunities. - As part of this effort, DIO will undertake staff-level focus groups into underlying reasons for lack of trust and fear of retaliation and develop a targeted proposal on strengthening programs in support of organizational cultural change by Q4 CY2023. - Staff surveys: - The upcoming Staff Engagement Survey (SES) will be the first comprehensive staff survey since 2017 and following the Covid-19 pandemic, setting a benchmark of staff sentiment on staff voice and trust issues. - Annual pulse surveys will follow to provide regular staff feedback on evolving sentiment in light of IP actions. *Source: Implementation Plan in Response to Recommendations of the 2022 Institutional Safeguards Review (selected excerpts).* ### Annex I. Matrix of Recommendation and Implementation Plan ### Annex I. Matrix of Recommendation and Implementation Plan ### DAI: Disclosure and Analysis Integrity — Recommendations, Implementation Status, Timelines, and Responsible Parties - DAI 1 — Clarify the terms of engagement of OED with staff in staff’s conduct of analysis - Support: In the Joint Statement this recommendation was endorsed. - Implementation actions: - (a) Engage with the Board to clarify and formalize the terms of engagement with staff. Implementation in form of a note that draws on longstanding good practices for OEDs’ engagement with staff in the conduct of analysis. The note will be shared with the Board (for OED) and issued by Management (as guidance to staff). - (b) Explore effective mechanisms to raise concerns by staff about undue influence. A note will present a range of options for staff to raise concerns of potential undue pressure. Options build on existing mechanisms and would allow for complaints to be raised at an early stage for early intervention and prevention, while also strengthening mechanisms to address undue pressure under the ethics framework. - Timeline: CY2023 Q1/Q2 - Resource/timing note: Accommodate within existing work programs - Responsible: SPR, LEG, and SEC, in close consultation with and with input from Board SG - DAI 2 — Clarify the role of management in the clearance of staff papers and positions - Support: In the Joint Statement this recommendation was endorsed. - Implementation actions: Implementation as Management guidelines to staff. A draft is being prepared for review by departments, to be issued to staff after finalization. - Timeline: CY2023 Q1 - Resource/timing note: Accommodate within existing work programs - Responsible: SPR, LEG, and OMD advisors - DAI 3 — Complete ongoing work to help ensure evenhanded coverage of emerging areas in surveillance - Support: In the Joint Statement this recommendation was endorsed. - Implementation actions: Implementation as Management guidelines to staff. These guidelines are guided by the Fund’s evenhandedness framework and Board-approved strategies on climate and gender, among others. A draft is being prepared for review by departments, to be issued to staff after finalization. - Timeline: CY2023 Q1 - Resource/timing note: Accommodate within existing work programs - Responsible: SPR - DAI 4 — (a) Further strengthen the transparency and documentation of the internal review process, and (b) assess how it has adapted to the Integrated Digital Workplace (IDW) - Support: In the Joint Statement this recommendation was endorsed. - Implementation actions: - (a) Implementation as Management guidelines to staff. A draft is being prepared for review by departments, to be issued to staff after finalization. - (b) Assessment of adaptation to the IDW will commence after the IDW rollout. - Timeline: (a) CY2023 Q1; (b) will commence after the IDW rollout. - Resource/timing note: Accommodate within existing work programs - Responsible: SPR, OIA ### EP: Ethics and Protections — Recommendations, Implementation Status, Timelines, and Responsible Parties - EP1 — Standards, procedures, and rules that apply to the Managing Director and the Executive Directors should be higher than those set for staff - Support: The Joint statement agreed to review the ethical frameworks applicable to the Board and management, and to propose changes as needed. The Board agreed to a full review of the Board Code of Conduct and the ethical framework applicable to the Managing Director. The review to be conducted by the Ethics Committee (See, EBAP/22/81). - Timeline: CY23 Q2/3 - Resource/timing note: Accommodate within existing work programs - Responsible: Ethics Committee, with input from the Legal Department and Ethics Advisor - EP2 — The Managing Director and the Deputy Managing Directors should publish the type of financial assets they hold yearly, as per the practice at the ECB or the European Commission - Support: The Joint statement agreed to a review of existing frameworks to enable the publication of summary statements of financial assets and interests of the MD and DMDs, in line with best practices in other international financial institutions, in time for the next annual disclosure program. - Implementation actions and status: Staff have benchmarked practices and prepared a proposal to Management. Management has agreed on a framework to apply to DMDs, by which summaries of their disclosures would be published at the end of the next annual financial disclosure process in the latter half of 2023, and annual thereafter. Management’s views on the framework would be conveyed to the Ethics Committee once it is in place so it can agree a similar framework for the MD. - Timeline: CY23 – Q1/2, for necessary decisions to be approved in time for the next annual disclosure program in Q2/3. - Resource/timing note: Accommodate within existing work programs - Responsible: Ethics Office in consultation with OMD, Board Ethics Committee and LEG - EP3 — The personnel of OED should be granted access to all parts of the Dispute Resolution System (DRS), including the informal mechanisms - (A) OED Access to Informal DRS - Support: The Joint statement agreed to take steps to expand access of OED employees to the informal dispute resolution mechanisms. - Implementation actions: Staff are preparing a proposal to be considered by the Board. Key elements: (i) all OED personnel being granted access to the Ombudsperson (OMB) and Mediator (MDT); (ii) OMB and MDT granted direct access to EDs for this purpose, and to share information relevant to matters being considered. Reporting modalities will be discussed. Committee on Administrative Matters (CAM) to consider the proposal in CY2023 Q1, with a target completion date of April 2023. - Timeline: CY23 Q2 - Resource note: Net budget to be determined - Responsible: CAM, LEG, and SEC, in consultation with OMB and MDT - (B) OED Access to Formal DRS - Status: Requires further consultation. - Rationale and issues: Granting access to formal dispute resolution mechanisms (administrative review processes, Grievance Committee, Administrative Tribunal) would require a fundamental review of OED governance and member/constituency impact on personnel decisions, and consideration of amendments to review channels. Currently OED personnel have selective access to Administrative Tribunal in certain respects. CAM to consider the broader issue at a later time based on experiences gained from granting access to informal DRS offices. - Timeline: Revisit Issue end-CY2024 - Resource note: Net budget to be determined - Responsible: CAM with support from LEG and SEC - EP4 — The Board should underscore the independence of the Ethics Committee by changing its composition to include majority of individuals who are not members of the Executive Board - Status: Insufficient Support - Rationale: The Ethics Committee reviewed benchmarking of eight comparators; in seven comparators the ethics committee is composed solely of board directors. Only the ECB has an ethics committee entirely of external individuals; ECB’s institutional context differs. Practical constraints noted for external members participating in time-sensitive and confidential matters. The Ethics Committee recommends that the Board decline to implement this recommendation. - Timeline/status fields: n/a - EP5 — In cases involving the conduct of the Managing Director, the Secretariat of the Ethics Committee should be an external lawyer rather than staff of the Fund - Status: Requires further consultation - Current practice and rationale: Board Code of Conduct provides that the General Counsel, or representative, is the permanent secretary of the Ethics Committee. The Ethics Committee has an external “ethics consulting firm” on retainer for investigative services under the Committee’s direction. The General Counsel provides independent, objective legal advice to multiple parties and may issue legal opinions on his/her own authority and directly to the Executive Board without seeking clearance from the Managing Director. Benchmarking of eight comparators suggests replacement of the Secretariat by an external body is not present in rules of the benchmarked organizations. The question will be further considered in the context of the full review of the Board Code of Conduct targeted for completion in 2023Q2/3. - Timeline: CY 2023 Q2/3 - Resource note: Net budget to be determined - Responsible: Ethics Committee - EP6 — The Managing Director and the Board should lead culture change efforts across the Fund, making a culture of dialogue and integrity a strategic priority - Support: Management and the Board to champion and support measures aimed at strengthening protections against bullying, harassment, and retaliation. This recommendation underpins the success of EP Rec. No 27(30). - Key deliverables where Management and Board to engage include: - i) Townhall on IP (including covering guidance notes for Staff and OED), January 2023. - ii) Update to staff from Management following annual consultation arrangement between the DRS offices with Management and the Board (EP Rec. 14). - Timeline: From CY22 Q4 onwards - Resource/timing note: Accommodate within existing work programs - Responsible: COM in collaboration with HRD and DRS - EP7 — Unethical conduct should be penalized consistently, and sanctions communicated to staff (e.g., regular anonymized reporting on cases and consequences) - Support: Consistency in sanctioning misconduct is integral to fairness, due process, and trust. - Implementation actions: HRD and LEG regularly liaise to ensure penalties imposed on B-level staff, A-level staff and contractual employees are consistent and will continue to do so. OII will augment its 2021 Annual Report (released by end-CY22) to provide more substantive summaries of cases and outcomes, balanced with confidentiality considerations. - Timeline: On-going - Resource/timing note: Accommodate within existing work program - Responsible: Office of Internal Investigation (OII) - EP8 — Retaliation: strengthen anti-retaliation policy and practice. Specific sub-recommendations and responses: - (i) Amend rules to require the alleged wrongdoer to bear the burden of explaining their action did not have a retaliatory motive - Status: Insufficient support - Rationale: The Fund’s Retaliation Policy establishes an Independent Review (IR) process with a high standard of proof ("clear and convincing evidence that the same adverse action would have been taken, for separate and legitimate reasons, even in the absence of the complainant’s protected activity"). This grants strong protection to employees where doubt exists. Shifting the burden of proof to subjects of allegations would conflict with presumption of innocence and international jurisprudence; thus no change is appropriate. - Timeline/status fields: n/a - (ii) Where IR concludes retaliation occurred, consider that finding in performance evaluations with appropriate consequences attached - Support: An IMF employee’s failure to abide by the Retaliation Policy is addressed as a performance management issue. If the misconduct process finds individual responsibility, appropriate sanctions will be considered and imposed per established processes. - Implementation note: An IR may find institutional responsibility without establishing individual culpability; managers may still critique performance and refer performance issues to evaluations. The Responsible Official considers whether such findings are shared with departmental management for inclusion in performance reviews. - Timeline: On-going - Resource/timing note: Accommodated under existing work program - Responsible: OII in consultation with HRD and Management - (iii) Amend rules to require an investigation for individual responsibility in all cases where IR concludes retaliation occurred - Support with modification: Continue current practice of assessing, on a case-by-case basis and under the existing provisions of Staff Handbook GAO 11, Chapter *Italic: Source — Annex I. Matrix of Recommendation and Implementation Plan (implementation plan in response to recommendations of the 2022 Institutional Safeguards Review).* ### 11.02 and Sections 4.1 and 4.4 of the ### 11.02 and Sections 4.1 and 4.4 of the Retaliation Policy, individual misconduct by Fund staff and whether retaliation claims brought forward by complainants represent matters warranting full investigation ### Revisions to Retaliation Policy and investigative linkage - Add a provision to Section 4.4 of the Retaliation Policy requiring that, when the OII Independent Review determines that retaliation has occurred, OII’s report to management (B-level) or the Director, HRD (A-level) recommending corrective measures will also advise as to whether OII will request authorization to conduct an investigation into individual misconduct, per the provisions of GAO 11, Chapter 11.02, Section 4.3. - Support: Revisions to the Retaliation Policy are being prepared to provide for advice and early informal resolution for those who fear retaliation (per External Panel’s recommendation for increased reliance on informal resolution). These include adding provisions to make it clear that: - Supervisors may seek confidential guidance and advice from OII. - Employees can utilize the informal Dispute Resolution channels (Ombuds, Mediation) to attempt to resolve the issue and can consult with HSD’s Counselling Unit as needed. Attempts at early dispute resolution will not preclude the complainant from filing a formal complaint with OII and a rule would be drafted to address the extension of relevant timelines. - Timing and budget impact for these revisions: - CY23 Q1-2 - Accommodate under existing work program - Net budget impact to be determined if training and outreach initiatives are envisioned - Responsible: OII, in consultation with HRD, LEG, ETO and DRS. ### Communication and awareness-raising actions - Fund-wide communications are being implemented to raise awareness of: - (i) the mechanisms available for staff to raise concerns, including around issues of undue influence; and - (ii) the existing measures for protection from retaliation where these mechanisms are pursued. - Two “flagship” events: - (i) An awareness-raising event to share information with all staff on the various DRS offices, the Ethics Office, and OII, and mechanisms available to them, including to protect against retaliation (December 2022); - (ii) A formal townhall with heads of the DRS, Ethics Office, and OII, as well as with SAC, which will provide an opportunity to present and discuss with staff the actions/reforms that will be undertaken in response this Review (January 2023). - Additional FY23-FY24 communication products: - an updated DRS website, informal listening sessions with groups of staff, digital signage, special #StayConnected videos, and an intranet article and infographic explaining the roles of and differences among DRS offices. - Timing and delivery: - December 2022; January 2023 - Accommodate under existing work program - Responsible: COM, in collaboration with DRS offices and HRD. ### Whistleblower Policy development - Management agrees to develop a standalone Whistleblower Policy, which confirms that employees who raise concerns of ethical concerns are protected from adverse action. While these protections are embedded in the Fund’s rules, including the Retaliation Policy and the Integrity Hotline policy, consolidating these in a standalone Whistleblower Policy will serve as an important signal from Management to staff about the protections available. - A Task Team, comprised of ETO HRD, LEG, OII and SAC will prepare a draft policy for management’s consideration, and will consider any necessary amendments to the Retaliation Policy to avoid duplication. - Timing and resourcing: - CY23 Q4 - Accommodate under existing work program - Responsible: ETO, HRD, LEG, OII and SAC. ### Training, supervisory responsibilities, and culture change - Recommendation: Training should be offered to staff and employees about their rights and the available measures of protection from retaliation. All supervisors should be better trained on how to avoid behaviors that could amount to retaliation. - Support measures agreed: - The Joint statement agreed to revise the Retaliation Policy to include affirmative supervisory responsibility to report misconduct or retaliation concerns of which they become aware. - a. In all cases where supervisors or managers receive a report of misconduct and/or concerns about retaliation (excluding those for which they are a subject), they must seek to address it promptly by reporting it to OII or seeking guidance and advice from ETO and DRS offices. In cases where the supervisor or manager themselves are implicated, they are required to advise their immediate supervisors of such reports (who would then be required to report the matter to OII or seek guidance). - Timing: CY23 Q1/2 - Accommodate under existing work program - Responsible: OII, in consultation with HRD, LEG, ETO and DRS. - b. Adjustments to management training programs will be assessed under the cultural change workstream (EP Rec No. 30). ### Interim protective measures for complainants and witnesses - Recommendation: The Fund should proactively determine whether interim protective measures are needed for the complainant or witnesses and, with the consent of the potential/alleged victim, to recommend the urgent implementation of such measures to Management/HRD, without requiring the alleged victim to request such measures. - Support: The Joint statement agreed to revisions to the current Retaliation Policy to create a positive obligation on the Internal Investigator to consider the implementation of interim measures in all cases involving allegations of retaliation and to formally document their consideration. *Source: ppea2022061 - 11.02 and Sections 4.1 and 4.4 of the Retaliation Policy (implementation plan excerpts). * ### conclusion (2023Q1-2). These include ### conclusion (2023Q1-2). These include ### Retaliation policy, access to Independent Review, and interim protections - Recommendation: Expressly state that remote work, temporary reassignment, transfer, or change in duties will be considered for the complainant or the alleged retaliator. - Make clear that, in making this determination, the interests of, and the impact on, the complainant, the alleged retaliator, and the business needs of the Fund should be considered. - Timeline/Action: CY23 Q1/2 — Accommodate under existing work program. Responsible: OII, in consultation with HRD, LEG, ETO and other DRS offices. - Recommendation (vii): Extend the period for access to Independent Review with special protective standard of proof for retaliation claims to 3 years from the alleged retaliatory act. - Current rule: Retaliation requests for an IR of an adverse action must be made within 6 months of its occurrence; allegations outside that time limit are subject to the standard misconduct investigation process. Allegations of misconduct, including harassment, discrimination, and abuse of authority, are not subject to any statute of limitation and may be reported at any time. - Review view: IMF statute of limitations for IR is shorter than comparators; recommendation viewed favorably but requires additional discussion to restructure the process, address related provisions, and consider implications for the Grievance process and other DRS channels. - Status: Requires further consultation. CY23 Q2 Q3 — Accommodate under existing work program. Transitional resources for consultations and redrafting applicable policies. Responsible: OII in consultation with HRD, SAC, LEG. ### Monitoring and measuring no-retaliation / speak-up culture - Recommendation (viii): Closely monitor, evaluate, and measure efforts and effectiveness of measures adopted to support a no-retaliation and “speak up” culture by doing more frequent surveys run entirely by external and independent providers. - Support / Action steps: - Staff Engagement Survey (SES) to include questions on trust, speak-up culture, and retaliation and to set a baseline (CY22 Q4, CY23 Q1). - Follow-up pulse surveys to the SES to measure progress on these issues in following 2 years. - Timeline: CY22 Q4- CY23 Q1. Implementation: Accommodate within existing work program. Responsible: HRD. ### Undue influence, political pressure, and related safeguards - Recommendation (ix): Develop and strengthen safeguards and mechanisms for dealing with allegations of undue influence or political pressure in the DRS. - Support: Joint statement agreed to broaden the terms of reference of both the Ombudsperson and Mediator to include dealing with allegations of undue influence by Management or the Board on Staff, at least until other mechanisms are in place. - Actions: Proposals to amend the Terms of Reference of the Ombudsperson and Mediator prepared by staff to make explicit the authority to consider allegations of undue influence. Amendments intended to support communications campaign to raise staff awareness of resources. - Timeline: CY22 Q4. Accommodate under existing work program. Responsible: LEG and HRD in consultation with OMB and MDT. - Additional: Ethics Advisor and Ombudsperson should consider convening Fund-wide roundtable discussions to develop shared norms on data analysis and integrity, speak-up culture, and a more specific policy for resolving these concerns when informal mechanisms prove insufficient. Interim protections from retaliation should be considered in such cases. ### Transparency of Ethics Committee and administrative review publications - EP9 (A): Information regarding outcomes of cases considered by the Board Ethics Committee should be made available to staff through publication of annual or other periodic reports. - Support: Board agreed to publish high-level information about number and nature of matters considered by the Ethics Committee and general disposition of these cases every two years, at the end of each Committee’s term (See EBAP/22/81). - Timeline: First report issued CY22 Q4. Accommodate under existing work program. Responsible: Ethics Committee. - Ethics Committee training: Approved training on the Board Code of Conduct for all new OED employees, including EDs, as part of onboarding and annual basis for serving EDs and OED employees. First overview provided November 2022; more detailed annual training planned for CY23 Q1. - First onboarding training conducted in November 2022; annual training planned for CY23 Q1. Accommodate under existing work program. Responsible: Ethics Committee. - EP9 (B): Promptly resume publication of information regarding the Administrative Review process and the Grievance Committee; Ethics Advisor should consider complaints of excessively redacted reports. - Support / Status: - On May 6, 2021, the Grievance Committee released its Annual Report for 2020 and 2021 via Fundall and posting on the Dispute Resolution System (https://drs) and Grievance Committee intranet sites. - Grievance Committee working to complete publication of redacted copies of its recommendations (dating back to 2018) on its intranet site by end CY22. - Grievance Committee not aware of past complaints about excessively redacted recommendations and will consider concerns if raised. - Grievance Committee Annual Report for 2022 will be published in 2023. - HRD will publish its Annual Report on Administrative Reviews for 2019, 2020, and 2021 on (https://drs) at end-2022. The 2022 Annual Report on Administrative Reviews will be published in 2023. - Timeline: CY22 Q4 – CY23 Q4. Accommodate under existing work program. Responsible: Grievance Committee. ### Dispute Resolution System (DRS) consolidation, toolkit, case tracker, and transparency - EP10 (A): All DRS information should be available on one intranet webpage. - Status: Support. All DRS information has been available since 2018 on one intranet webpage: https://drs. The page includes links to each office and process, introductory information on the DRS processes, an introductory video, FAQs, and links to recent updates and events. - Status: Completed. Accommodate under existing work program. Responsible: COM, HRD. - EP10 (B): Create a Tool-Kit for Self-Represented employees on the DRS webpage with role descriptions, timelines, percentage distribution of outcomes for past 2 years, and detailed guidance. - Support: Implementation after Recommendation 35 (engagement of Staff Legal Counsel due CY23 Q2). The Staff Legal Counsel engaged will develop guidance materials as part of their Terms of Reference. - Timeline: CY24 Q2/3. Net cost: Net cost to be determined. Responsible: HRD, LEG and SAC. - EP10 (C): Post a real-time case “tracker” on a secure intranet page allowing staff to monitor progress of their cases. - Support / Interim solution: DRS offices to make clear clients may regularly request updates by email to a designated contact. A workstream led by ITD with Dispute Resolution System, LEG, and HRD will evaluate scope and cost of IT options and prepare a proposal for management consideration ahead of FY25 Capital budget discussions. - Timeline: CY24 Q3. Status: Yes. Net cost to be determined as part of workstream on case tracker. Costs includes transitional staff resources to develop proposal and potential recurring IT costs. Responsible: ITD in consultation with DRS, HRD, and LEG. - EP10 (D): Show nature of individual complaints filed by staff (past two to five years), timelines, substantiation status, recommended consequence or decision, and action taken including reasons if recommendations were not followed. - Support: Subject to further exploration dependent on implementation of EP Rec. 10(c). Information on nature of cases and outcomes is already made available on intranet sites for Office of the Mediator, OII, Administrative Review, the Grievance Committee, and the Administrative Tribunal (also via the DRS Home Page). An efficient approach could draw upon non-confidential information in the real time case-tracker. - Timeline: CY25. Net cost to be determined (see EP Rec. 10C). Responsible: LEG, in consultation with DRS, HRD, and COM. ### DRS employment framework and workforce planning - EP11: Implement changes made to the DRS employment framework in early 2021 to allow DRS leaders and employees to elect conversion to staff positions with full benefits for the remainder of their terms. - Position: Support with modification. Correction: 2021 amendment did not provide for immediate reclassification of all contractual employee positions into staff positions, nor conversion of employees in such positions to staff. - Management view: DRS offices must conform with the Fund’s Categories of Employment (COE), which includes a mix of appointment types (staff, contractual, and vendor services) applied Fund-wide, to be assessed following a workforce planning exercise and competitive selection processes for staff appointments. Recommendation to allow current employment “to elect conversion” is not supported. - Workforce planning actions: - Develop workforce plans for employees of DRS offices in line with COE; five structural staff positions already allocated to offices in FY23 budget as part of a 30 percent increase in their budgets. - HRD will work with DRS offices to formalize DRS workforce plans to form basis for budget discussions within six months for implementation beginning in FY24. - Heads of office positions: - Use of fixed-term staff appointments for four DRS Office Head positions (ETO, MDT, OII, OMB) would require amendment to 2014 Categories of Employment Board Paper (EBAP/14/89) to create a new category of term appointments specific to DRS Offices with measures to protect independence. - Task Team (HRD, LEG, SAC) to prepare for 2023 Q3 a draft Board paper to establish new category of staff appointment for these positions. Expected to affect four Office Head positions. - Task Team will prepare a fully costed proposal for Management and Board decision (approximately $110,000 per position). - Timeline: CY23 Q2 onwards; CY23 Q3 for draft Board paper. Net costs for employees of offices to be determined based on workforce planning, supported by HRD and discussed in the context of the regular budget process. Net cost for Heads of offices to be determined as part of workstream on Employment Framework. ### OII investigatory authority and centralization of investigations - EP12: OII should not require authorization from Management or HRD before investigating cases. Create Terms of Reference for OII. - Support: Change to be reflected in next update to the Staff Handbook (CY23 Q1/2) and incorporated into OII’s terms of reference. OII will continue to report to Management regarding matters that merit such communication to address operational or other risks, conflicts of interest, or to recommend interim/protective measures. - Timeline: CY23 Q1/2. Accommodate under existing work program. Responsible: OII. - EP13: Investigations of allegations of misconduct should be centralized and conducted by OII only — not by Departments within the Fund. - Support: Appropriate to centralize entry point and allow OII as focal point to re-route allegations for appropriate action. Aligns with OII’s administration of the Integrity Hotline and supervisors’ and staff reporting obligations. - Timeline: CY23 Q1/2. Net Cost (if any) to be determined. Responsible: OII, in consultation with HRD and LEG. ### DRS leadership engagement and reporting - EP14: Heads of the DRS and related offices should have opportunity to report to the Board at least once a year and to meet with the MD as needed; meetings with the MD should not be delegated to Deputy MDs. - Support / Actions: - (i) Joint meeting at least once a year between Management and relevant DRS and Ethics and Integrity Offices to discuss respective annual reports. - (ii) Annual session for DRS and Ethics and Integrity Heads to brief the Board on efforts and activities. - (iii) Other informal engagements (e.g., retreat or luncheon) with the Board. - Timeline: CY23 Q1/2. Accommodate within existing work program. Responsible: ETO with DRS stakeholders. ### OIA independence and oversight - EP15 (A): OIA should be independent; requirement to have its workplan approved by management should be abolished. - Position: Support with modification. Most IFIs: Management approves Internal Audit work plan; Audit Committee also approves in parallel. At the Fund, External Audit Committee (EAC) reviews OIA’s Program of Work but does not approve it. - Proposed change: Introduce additional step for the EAC to approve OIA’s Program of Work. If Management suggests modifications, OIA Director will communicate those to the EAC along with proposed disposition. In case of divergence, Director of OIA shall make an appropriate judgment and document reasons. - Implementation implication: Would require amendment to OIA and EAC Charters. Implications of further measures to strengthen OIA independence need careful examination due to OIA’s internal advisory role. - Timeline: CY23 Q1/2. Accommodate within existing work program. Responsible: OIA. - EP15 (B): Establish an “internal” Audit Committee of the Executive Board so OIA can report directly to them. - Position: Insufficient support. Rationale: - Creating an Internal Audit Committee of the Board would assign a supervisory role to what is an executive function, potentially creating conflict of interest as the Board would in practice be auditing its own work. - Historical context: By-Law section 20 originally provided for Executive Board to “have an audit of the accounts of the Fund”; By-Law 20 amended in 1947 to establish an External Audit Committee selected by MD and appointed by Executive Board to provide independent external audit. - Internal Audit functions in comparator IFIs do not report directly to an Audit Committee; they report administratively to Management and have functional reporting relationships with Audit Committees of the Board. OIA’s prior External Quality Assessments (EQAs) confirmed OIA’s functional and administrative reporting relationships support independence and objectivity. - Position: No action proposed within Institutional Safeguards Review for this recommendation. *Implementation Plan in Response to Recommendations of the 2022 Institutional Safeguards Review — conclusion (2023Q1-2)* ### 2021. In particular, the Fund ### ppea2022061 - 2021. In particular, the Fund ### Risk management governance and oversight - The Fund should strengthen ORM’s challenge function as the second line of defense, both in the core and administrative areas of the Fund. - Support ORM has developed a comprehensive action plan to respond to the 2021 OIA Audit of the Fund’s ERM Framework. ### Implementation, validation, and reporting - OIA will validate the implementation of these actions per the committed target dates. - OIA will independently report on the status to the External Audit Committee and the Board. - It is anticipated that the Fund’s Executive Board will approve the ERM Policy in December. *pp ea2022061 - 2021. In particular, the Fund* ### 2022. In this proposed ERM Policy, the Second ### IMPLEMENTATION PLAN IN RESPONSE TO RECOMMENDATIONS OF THE 2022 INSTITUTIONAL SAFEGUARDS REVIEW ### Oversight, Risk Management, and Office of Risk Management (ORM) - Second Line, defined as the Office of Risk Management, will provide oversight of enterprise risks, independent of the First Line, across the Fund’s core, functional, and support activities in a manner that addresses the OIA ERM Audit (April 2021) and that is consistent with approaches at other International Financial Institutions. - Timeline: CY24 Q1/2. - Implementation approach: Accommodate within existing work program. - Responsible: ORM. ### Office of Internal Audit (OIA) capacity, monitoring, and reporting - Finding: OIA has secured an increase in its structural budget envelope for FY23; no specific additional action required now, with ongoing evaluation through annual budget cycle and accountability framework discussions. The OIA Director can flag adequacy issues to the External Audit Committee. - Status: On-going. - Actions to strengthen monitoring of OIA and IEO recommendations: - Link reporting of implementation status of OIA and IEO recommendations to Departmental Accountability Framework discussions. - OIA initiated a triage exercise to reassess severity and enterprise risk profile of open audit issues; initiative endorsed by FRC and External Audit Committee (EAC). - OIA will publish a dashboard of open and overdue actions to increase visibility to Department Heads, FRC, EAC, and the Board. - ORM is developing a structured framework for tracking and reporting issue and action management. - Milestones and timelines: - Departmental Accountability Frameworks – CY23 Q2. - Completion of OIA Triage Exercise – CY23 Q1. - Publication of OIA Dashboard – CY23 Q1. - Ongoing validation/reporting of IEO recommendations through Periodic Monitoring Reports (twelfth PMR scheduled for Board in November 2022). ### Dispute Resolution System (DRS) and Grievance Committee reforms (EP17, EP39, EP35, EP36, EP37, EP38, EP40) - EP17: Incentivize/prioritize time for peer reviewers, witnesses, and others to process disputes more efficiently through DRS (including OII, Grievance Committee, Administrative Tribunal). - Finding: Grievance Committee delays sometimes due to scheduling difficulties for panel members, witnesses, legal representatives. - Action: Workstream (Grievance Committee Chair, LEG, HRD, SAC) to develop proposals to make Grievance Committee less formal and more efficient (see EP39). Proposals may include: - Formal inclusion of service in Grievance Committee members’ work program. - Permitting Grievance Committee members a certain number of designated business days to support this work. - Use of remote hearings if necessary. - Empowering the Grievance Committee to fix mandatory hearing dates, absent exceptional circumstances. - Rules enabling parties to opt for adjudication by the Grievance Chair sitting alone. - Scheduling hearings during agreed session “windows” outside traditionally busy periods (e.g., Annual and Spring Meetings). - Possible Staff Rule/provision to Code of Conduct requiring former staff to give witness evidence in necessary cases. - Timeline: CY23 Q4. - Implementation approach: Accommodate within existing work program. - Responsible: Grievance Committee Chair, LEG, HRD, SAC. - EP39: Re-brand/re-cast Grievance Committee into a peer review mechanism to be faster and less judicialized. - Finding: Grievance Committee is a hybrid arbitration/peer-review system that has become more legalistic and time-consuming; views diverge (SAC does not support change). - Action: Task Team (Grievance Committee Chair, HRD, LEG, SAC) to review comparator practices and develop proposals to reduce formality/litigiousness and refocus on fact-finding; prepare proposals in conjunction with Staff Legal Advisor (EP35) and EP17 by Q4 CY2023. - Timeline: CY23 Q4. - Net cost (if any): to be determined. - Responsible: Grievance Committee Chair, HRD, LEG, SAC. - EP35: Establish a Staff Legal Counsel (SLC) to advise/represent staff in employment-related matters before DRS. - Finding: Broad support in principle; multiple models exist across comparators requiring detailed consideration of scope and terms. - Action: Task Team (Grievance Committee Chair, HRD, LEG, SAC) to prepare proposal for management by Q4 CY 2023; consider in parallel with EP17 and EP39; assess resource implications for FY25 budget process. - Timeline: CY23 Q4. - Net cost: to be determined. - Responsible: Grievance Committee Chair, HRD, LEG, SAC. - EP36: Make first step of Administrative Review mandatory for benefits disputes, optional for other types. - Position: Management supports mandatory first step for benefits disputes; recommendation to make first step optional for other cases to be considered further with EP32 and EP37. - Action: Task Team (HRD, LEG, SAC) to prepare proposal for management approval by Q3/4 2024; anticipate first step optional for all matters other than performance appraisal. - Timeline: CY24 Q3/4. - Net cost: to be determined. - Responsible: HRD, in consultation with LEG and SAC. - EP37: Introduce short, enforced timelines for administrative review cases (e.g., 20 days for performance review disputes) with consequences for missed timelines. - Position: Requires further consultation. Management supports Task Team (HRD, LEG, OII, SAC) to prepare proposal incorporating benchmarking and careful balancing against unintended consequences. - Actions: From 2023 onwards HRD will separate recording of time for review process vs. resolution initiatives to depict actual review time more accurately; Task Team to consider consequences for missed timelines (e.g., reimbursement of reasonable legal fees). - Timeline: CY24 Q3/4. - Net cost: to be determined. - Responsible: HRD, in consultation with LEG and SAC. - EP38: Ensure HR, DRS, and related offices are adequately staffed; thorough, objective, transparent evaluation of resources needed. - Finding: FY23 review led to a 30 percent increase in DRS resourcing, including provision of 5 staff positions. - Action: Beginning with FY24 cycle, DRS Offices to work with HRD to formalize workforce plans for budget discussions within six months for FY24 implementation; HRD’s Administrative Review functions continue to follow annual budgeting process. - Timeline: CY23 Q2. - Net cost of staffing: to be determined. - Responsible: OBP, HRD in consultation with DRS offices. - EP40: Create a standardized form for filing administrative review requests, including section for desired measures to memorialize date and encourage informal resolution. - Action: HRD commenced work on a standardized online Administrative Review Intake Form (including a section asking the requester to describe desired action) and an Exit Questionnaire. - Timeline: CY23 Q1. - Implementation approach: Accommodate within existing work program. - Responsible: HRD. ### Transparency, retaliation, ethics, and consequences (EP18, EP19, EP20, EP21, EP22, EP23, EP24, EP25, EP26) - EP18: Weigh confidentiality vs. transparency on misconduct; err on side of transparency for substantiated allegations; impose significant, visible penalties. - Position: Support with modification. Recommended actions include imposing appropriate and consistent sanctions for substantiated misconduct; transparency and consequences to be addressed in EP Rec. No. 7. Creation of peer review panel not pursued due to privacy, administrative challenges and consensus not to implement that element. - EP19: Visible, strategic and frequent communication of the Managing Director’s stance against retaliation; visible action when retaliation substantiated. - Actions: - Anonymized reporting can include general information that corrective measures were taken following a finding of retaliation by OII. - Timeline: CY23 Q4. - Implementation approach: Accommodate within existing work program. - Responsible: OMD, in consultation with COM, OII, and HRD. - EP19(B): Quiet changes won’t build support; visible, transparent, decisive action recommended. - Timeline: CY22 Q4 onward. - Responsible: OII, HRD, LEG. - EP20: Managing Director to host roundtable discussions with Ethics Office/Ombudsperson to generate buy-in and shared expectations on workplace challenges. - Position: Support with modification. Managing Director and Deputy Managing Directors to signal support through messages, townhalls, meetings. - EP21–EP23: Strengthen Board engagement and Code of Conduct to address political pressure on data integrity, build shared understandings, and hold Executive Board accountable to ethical standards. - Actions: - Steering Group and Board engaged in clarifying terms of engagement between staff and Board; work due in CY23 Q1/2 (See DAI Rec. No. 1). - Comprehensive review of Board Code of Conduct being conducted CY23 Q1/2; Code review timeline noted as CY23 Q1/2 and CY23 Q2/3 for review. - Implementation approach: Accommodate within existing work program. - Responsible: Board. - EP24: Complainants should not be required to be reassigned; alleged perpetrators, not complainants, should bear inconvenience when misconduct substantiated. - Position: Support with modification. Where misconduct is found, disciplinary action is taken against the subject, not the complainant. Interim protective measures and strengthened retaliation process policy are in place. New whistleblower policy referenced (see EP8). - Timeline: CY23 Q2/Q3. - Responsible: OII, in consultation with HRD, LEG, SAC. - EP25: Staff who serve as peer reviewers, witnesses, or assist DRS should receive acknowledgement in performance reviews. - Action: HRD will review APR guidance for 2023 APR cycle to ensure such contributions are recorded and considered; encourage managers to seek input from Grievance Committee Chair. - Timeline: CY2023 Q2. - Implementation approach: Accommodate within existing work program. - Responsible: HRD. - EP26: Create accountability measures for HRD, LEG, and managers to reduce litigiousness; missed timelines reflected in performance reviews. - Position: Support. When individual performance deficiencies cause missed deadlines, performance reviews reflect that and influence promotions. - Status: On-going. - Implementation approach: Accommodate within existing work program. - Responsible: HRD, LEG. ### Culture change, training, and employee engagement (EP27, EP28, EP29, EP30, EP31, EP32, EP33) - EP27–EP29: Encourage supervisors and employees to engage in collaborative problem-solving, seek facilitation from Ombudsperson/Mediator, ask for help, and volunteer for DRS roles. - Actions: - Leverage Departmental initiatives from 2021 D&I Survey (e.g., facilitated discussions) to encourage behaviors aligned with IMF competency framework and Core Values. - “If you see something, say something” multimedia campaign in collaboration with COM and DRS Offices. - Timeline: CY23 Q2 through CY25 Q4 for campaign. - Implementation approach: Accommodate within existing work program. - Responsible: All departments; HRD in collaboration with COM and DRS Offices. - EP30: Launch Fund-wide Culture Change Program to establish organizational culture of dialogue and integrity and promote “speak up” culture. - Position: Requires further consultation. - Actions: - Cultural change workstream to undertake inventory of past/ongoing initiatives and resources; conduct focus groups/interviews and define current culture drivers, root causes of lack of trust and fear of retaliation, and articulate future state culture. - Analysis period: CY22 Q4 to CY23 Q4. - On basis of analysis, propose modifications to programs and assess resource implications for FY25 budget process. - Timeline: CY23 Q4 for analysis completion. - Net cost: to be determined in the budgetary process. - Responsible: HRD. - EP31: Establish Ethics Ambassadors Program as part of Culture Change Program. - Position: Support with modification. Existing Peers for a Respectful Workplace (PRW) Program already encompasses ethics; Mediator organizes mandatory training including “Ethical Workplace” module delivered by Ethics Advisor. - Action: Ethics Advisor to strengthen training for PRWs to raise Ethics awareness and empower escalation of systemic ethics concerns. - Implementation approach: Accommodate within existing work program. - Responsible: Mediator. - EP32: Create an Employee Relations Unit within HRD, separate from Administrative Review team, to enhance timelines and early dispute resolution. - Position: Requires further consultation. - Action: HRD to prepare proposal for management decision on staffing structure changes, taking account of Recommendations 36 and 37; include benchmarking of similar teams and consider flexible staffing modalities; proposal to be assessed as part of FY25 budget process. - Timeline: CY23 Q4. - Net cost: to be determined. - Responsible: HRD. - EP33: Require parties to first participate in problem-solving conversations facilitated by Employee Relations Specialist/Mediator/Ombudsperson. - Position: Insufficient support for mandatory requirement because voluntariness underpins informal processes. Management supports encouraging increased usage of Ombudsperson and Mediator early in disputes. ### Administrative Tribunal, lessons learned, and access (EP34, EP41, EP42) - EP34: Provide transparent learning process on Administrative Tribunal (AT) cases; LEG to draft lessons learned memos when the Fund defends and loses. - Action: LEG’s existing practice includes memorandum to management on all AT decisions; going forward LEG will include a specific Lessons Learned section. Annual management statement in DRS report will reflect lessons learned. - Status: On-going. - Implementation approach: Accommodate within existing work program. - Responsible: LEG. - EP41: Devote greater efforts to offer a comparable position within the organization to employees wrongfully terminated. - Action: Task Team (HRD, LEG, SAC) to prepare proposal for management approval considering a new Staff Handbook rule on reinstatement decision-making protocol. - Timeline: CY23 Q4. - Implementation approach: Accommodate within existing work program. - Responsible: HRD. - EP42: Ensure all employees (including contractual employees) have same access to DRS and related offices. - Position: Requires further consultation. Contractual employees already access informal DRS mechanisms; access to formal mechanisms raises legal regime issues. Arbitration procedure for contractual employees exists since 1993, amended to allow similar procedural safeguards to staff grievance process. - Action: Working group led by senior management will develop proposals for amendments to dispute resolution procedures applicable to contractual employees. - Timeline: CY24 Q4. - Net cost: to be determined. - Responsible: LEG, HRD, SAC, Ombudsperson. *Source: Implementation Plan in Response to Recommendations of the 2022 Institutional Safeguards Review (extracted content).* --- _Source: https://www.imf.org/-/media/files/publications/pp/2022/english/ppea2022061.pdf_