## ppea2023060

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**Canonical URL:** [ppea2023060](https://www.imf.org/-/media/files/publications/pp/2023/english/ppea2023060.pdf)

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---

### EXECUTIVE SUMMARY — Overall implementation progress
- Institutional Safeguards Review (ISR) completed and discussed by the Executive Board in June 2022.
- Board-endorsed Implementation Plan (IP) developed and discussed by the Board in December 2022.
- IP comprised 70 in-train or planned actions tracked through a consolidated “Action Tracker”.
- Substantial progress on actions targeted for completion in CY2023: 85 percent of the actions having been completed or remaining on track for completion by end of CY2023.
- Some actions defined for implementation in CY2024; efforts to complete pending CY2023 actions remain broadly on track as IP implementation approaches the completion of a full year following Board endorsement.

### EXECUTIVE SUMMARY — Implementation monitoring and validation
- IP set responsibilities, timelines, and a monitoring framework; actions grouped under four key themes: (i) Data Analysis and Integrity; (ii) Leadership: Tone from the Top; (iii) Building Trust in and Strengthening DRS, Ethics, and Investigation Offices; and (iv) Oversight and Accountability.
- ISR Program Lead appointed to coordinate implementation, track completion, and support progress reporting.
- Action Tracker aligns with Management Implementation Plan (MIP) Board reporting practice and used for periodic status update discussions.
- Office of Internal Audit (OIA) will conduct an independent assessment of ISR implementation in CY2024, consistent with OIA’s Periodic Monitoring Reports (PMRs).

### EXECUTIVE SUMMARY — Key data analysis and integrity actions and status
- IP recommendations: #1A, #1B, #2, #3, #4A, #4B focused on clarifying terms of engagement of OEDs, mechanisms for staff to raise undue influence concerns, clarifying Management’s role in internal clearance, evenhanded coverage of emerging areas, transparency of internal review, and CRS rollout assessment.
- All recommendations except #1B and #4B fully actioned through issuance of specific guidance.
- Joint note clarifying terms of engagement between Offices of Executive Directors (OED) and staff issued in June 2023; staff guidance issued by Management and relevant sections applicable to OEDs concurrently approved by the Executive Board.
- Guidance applies to surveillance, lending, capacity development, corporate and support functions, in the field and at headquarters, and requires close monitoring by first-line departments.

### EXECUTIVE SUMMARY — Leadership, ethics, and tone from the top
- Summary statement on the Board Ethics Committee’s activities published for all staff for the first time in November 2022.
- Regular schedule of ethics training for all OED personnel introduced; first session delivered in Q1 of CY2023.
- Executive Board approved a proposal to provide all OED personnel access to the Fund's Ombuds and Mediation offices.
- Review of the Board’s Code of Conduct and the ethical framework for the Managing Director underway; final recommendations expected to be tabled for Board consideration in the first half of CY2024.
- Framework for publication of summary financial statements and interests of the Managing Director and the Deputy Managing Directors finalized; first summary statements to be published on the Fund’s external website by the close of CY2023.

### EXECUTIVE SUMMARY — Building trust in and strengthening DRS, Ethics, and Investigation Offices
- IP actions aim to shift focus toward prevention and early, informal resolution and to streamline formal DRS processes.
- Greater access to DRS Offices’ results advanced through a joint meeting between Management and the DRS, Ethics, and Investigation Offices and a Management-chaired informal Board briefing.
- Executive Board approved changes to the DRS Employment Framework in June 2023 to align roles with comparator IFI organizations.
- Implementation of the FY24 workforce planning exercise resulted in a significant increase in structural budget and staffing for these Offices.
- Policy proposals to implement changes to the Retaliation Policy and misconduct procedures reflected in Staff Handbook updates.
- Whistleblower Policy development proceeding and expected to be finalized in Q1/Q2 of CY2024.
- Additional workstreams launched: identifying root causes for culture change, streamlining Grievance Committee procedures, and strengthening the employee relations function in HRD.

### EXECUTIVE SUMMARY — Oversight, accountability, and ERM
- OIA’s Charter amended to require External Audit Committee (EAC) approval of OIA’s annual Program of Work; EAC formally approved OIA’s FY24 Program of Work.
- Board approval of ERM Policy in December 2022 and Risk Tolerance (RT) framework in March 2023 put key building blocks in place.
- ORM actioned 2021 audit recommendations with a majority of actions validated and closed by OIA.
- Progress supports institutional accountability and independence.

### EXECUTIVE SUMMARY — Culture, measurement, and next steps
- 2022 Staff Engagement Survey (SES) provides a benchmark on staff sentiment around staff voice and trust.
- Monitoring framework will use targeted staff pulse surveys, risk culture surveys, and OIA assessments of ISR progress.
- Mainstreaming and operationalizing policy, process, and accountability changes will be a growing focus as implementation approaches a full year.
- Management commits to open and transparent information sharing via the ISR intranet webpage, including an “Action Tracker”.

*Prepared by the ISR implementation core group; update as of December 1, 2023.*

### BOX 1 — Shared Principles Underpinning Terms of Engagement between OEDs and Fund Staff — Shared principles
- Continuous and candid dialog between staff, OEDs, and national authorities is vital to Fund business.
- Independence of staff technical analysis and policy advice: staff should pay due regard to OEDs’ and national authorities’ views but must not be subjected to undue influence to alter their conclusions against their best professional judgment and relevant Fund rules and policies.
- Mutual respect and professional courtesy expected of all Fund personnel.

### BOX 1 — Management role, guidance, and documentation
- February 2023 guidelines clarify Management’s role in clearance of staff reports:
  - Management decisions to be taken on the basis of staff analysis and advice while Management retains prerogative to provide guidance on staff work and to exercise judgment on strategic issues within the Articles of Agreement and Board-approved policies.
  - Authoring and reviewing departments expected to bridge differences through dialog to limit Management arbitration to strategic issues.
  - Departments should not be discouraged from seeking Management arbitration when appropriate; disagreements and Management arbitration are part of healthy internal debate.
  - Management decisions are communicated in writing with explanations of considerations motivating the decision when resolving disagreements.
  - Authoring departments should present: (i) a concise and objective summary of issues requiring Management attention and decision; (ii) a candid presentation of issues raised in the review process; and (iii) a discussion of potentially controversial issues and implications of Management’s decision options.

### BOX 1 — Surveillance of emerging priority areas
- April 2023 interim guidance instructs staff to take an evenhanded approach to surveillance of emerging priority areas, including climate, digital money, gender, and to some extent inclusion issues, consistent with Board-approved strategies.
- Operational guidance will evolve; in-depth coverage where the Fund is still building capacity will be achieved over the medium-term for members where topics are macro-critical.
- Where capacity limitations impede upfront in-depth coverage, country teams should develop a plan to cover the issue in depth over the medium-term.
- Time horizon for coverage should match associated macroeconomic risks; country teams must balance coverage against other urgent priorities.
- Given resource constraints, in the short-term some countries will have had a deep dive analysis of a macro-critical area while some countries will have discussed these issues in a lighter way.

### BOX 1 — Interdepartmental review process and Common Review System (CRS)
- Guidance expands documents using the e-Review system for interdepartmental review and Management clearance.
- Work commenced on designing and implementing a Common Review System (CRS) to enable a more comprehensive, transparent, auditable, and traceable review process and accommodate future changes in review policies.
- OIA is concluding a benchmarking exercise of the Fund’s review process to inform assessment of how the review process will adapt to the rollout of the CRS (#4B).

### BOX 1 — Mechanisms to raise concerns of undue influence and related protections
- Terms of reference of the Ombudsperson and the Office of Mediation amended to make explicit authority to help staff address concerns of undue influence.
- Whistleblower Policy under development to provide further protection for staff raising concerns through appropriate channels.
- All Fund personnel have access to informal dispute resolution mechanisms and the Ethics and Investigation offices to raise concerns about undue influence.
- Finalization of related proposals expected in Q1/Q2 of CY2024.
- Note: Office of Internal Investigations (OII) does not have jurisdiction over Offices of Executive Directors (OED) and their staff; raising concerns about undue influence applies only for Fund staff/employees.

### BOX 1 — Leadership, tone from the top, and ethics transparency (actions completed or progressing)
- Summary statement on the Board Ethics Committee’s activities published November 2022.
- Regular schedule of ethics training for OED personnel introduced; first session Q1 of CY2023.
- Review of the Board’s Code of Conduct and Managing Director ethical framework underway; final recommendations expected first half of CY2024.
- Executive Board approved OED personnel access to the Ombuds and Mediation offices.
- First summary statements of the Managing Director and the Deputy Managing Directors to be published on the Fund’s external website by the close of CY2023.

### BOX 1 — Access to Ombuds and Mediation offices for OED personnel
- Executive Board approved in June 2023 granting all OED personnel access to Ombuds and Mediation offices on same basis as Fund staff.
- Access enables voluntary, informal, and confidential guidance; does not alter OED employment framework provisions on appointment and termination.
- Managing Director remains authorized to amend Terms of Reference of these offices as they pertain to staff.

### BOX 1 — Publication of financial summaries for leadership
- Ethics Committee proposed and Board agreed that current and future Managing Directors should be subject to publication requirements adopted for Deputy Managing Directors.
- Per finalized framework, first summary statements of the Managing Director and the Deputy Managing Director to be published by close of CY2023.
- Summaries posted for duration of Managing Director’s tenure plus a further period of two years (six months for the Deputy Managing Directors), thereafter removed from the Fund’s website but treated as “other documentary material” under the Fund’s Open Archives Policy.

### BOX 1 — Building trust in and strengthening DRS, Ethics, and Investigation Offices (actions and focus)
- IP actions to foster staff trust and confidence in DRS and ensure protection of staff voice and consistent, fair application of disciplinary and misconduct processes.
- Core focus shifted toward prevention and early, informal resolution while streamlining formal DRS channels.

### BOX 1 — Employment framework changes for DRS, Ethics, and Investigation Offices
- Executive Board approved changes in June 2023:
  - Hiring of future heads (Ombuds, Mediator, Ethics Advisor, Head, OII) on a staff term appointment with initial term of 3 years and possibility of one renewal for an additional period of six years (total period of 9 years), without prospect of open-ended employment.
  - Eliminating exemption for contractual employees in DRS, Ethics, and Investigation Offices from the four-year maximum under the Categories of Employment (CoE) framework after provision of additional FTE resources.
- Changes communicated through townhalls and briefings and are being operationalized.

### BOX 1 — Workforce planning and resourcing for DRS, Ethics, and Investigation Offices
- Completion and implementation of FY24 workforce planning exercise is critical to augment resourcing.
- Resourcing changes:
  - DRS, Ethics, and Investigation Offices collectively received the largest structural percentage increase in the Fund (24.6 percent) for FY24 budget allocations and about 47 percent after including transitional funds.
  - Builds on an overall 30 percent increase in DRS resourcing allocated to the Offices in FY23, with an overall upward shift in resources since FY2022 of about 80 percent.

### BOX 1 — Structured engagement and forward-looking considerations
- Structured engagement established: joint meeting between Management and the DRS, Ethics and Investigation Offices; Management-chaired informal Board briefing in June 2023.
- Forward-looking considerations: build capacity for open conversations, focus on conflict prevention and toolkits, enable lasting behavioral changes through change management, proactive communication of mandatory obligations.

### BOX 1 — Staff Handbook updates and procedural changes
- Staff Handbook updates include:
  - Clarifying duty of care to individuals reporting suspected retaliation by requiring Managers and supervisors to report suspected misconduct to OII.
  - Removing requirement for OII to obtain authorization from HRD Director or Management to initiate formal investigations.
  - Establishing OII as centralized entry point for misconduct allegations.
  - Incorporating express reference to proactive interim protective measures for complainants or witnesses of alleged retaliation.
- Revisions supported by targeted training and communications initiatives.

### BOX 1 — Access to information and disclosure improvements
- Annual Reports for CY2022 issued by Ethics Office, Ombuds Office, Mediation Office, OII, Administrative Review function, and Grievance Committee.
- Grievance Committee published redacted copies of its recommendations (since 2018).
- OII Annual Report disclosures augmented with summaries of cases and outcomes, balanced with confidentiality.
- Awareness-building activities and DRS Townhall convened in November 2023.
- HRD rolled out a standardized online Administrative Review Intake Form and an Exit Questionnaire.

*Source: ppea2023060 - Box 1. Shared Principles Underpinning Terms of Engagement between OEDs and Fund Staff*

### Strengthening institutional accountability and oversight — Measures taken
- (i) expand safeguards to preserve independence of OIA;
- (ii) enable systematic monitoring of remediation of open OIA and IEO recommendations;
- (iii) advance implementation of the “3 Lines” Model and strengthen the Fund’s ERM capabilities and processes.

### OIA independence, governance, and resourcing
- OIA’s Charter amended to require EAC approval of OIA’s annual Program of Work; EAC approved OIA’s FY24 Program of Work.
- OIA secured increases in structural budget envelope in FY2023 and additional transitional resources in FY2024.
- OIA Director can flag resource adequacy issues to EAC after exhausting internal procedures.

### Monitoring and remediation of OIA and IEO recommendations
- FY2023 triage exercise completed to give departments an accurate view of open audit issues; triage endorsed by Fund Risk Committee and EAC.
- Departments with significant progress in closing overdue actions include HRD, ITD, and CSF.
- Primary reasons for implementation delays: (i) competing work priorities within a resource-constrained environment; (ii) operational/implementation challenges.
- Departments provided revised target dates and OIA will support with departmental key contacts and guidance on expectations for action plans.
- IEO monitoring: OIA’s Thirteenth PMR discussed with the Board in November 2023.

### ERM operationalization and risk processes
- ERM Policy approved in December 2022; Risk Tolerance (RT) framework approved in March 2023.
- ERM Policy states all Fund activities are within ERM scope (surveillance, lending, CD, administrative and support functions).
- ORM to provide an “independent view and challenge” of enterprise risk management work and reporting by Departments.
- Departmental activities: RCSAs, DRSAs, Risk Event Reporting, Risk Treatments, and adherence to RT framework being undertaken; most departments completed at least one pilot RCSA.
- CSF implemented a third-party risk assessment and is progressing toward a comprehensive Third-Party Risk Management (TPRM) process.
- ORM actioned 2021 audit recommendations with majority validated and closed by OIA.
- Board to be briefed on specific areas (Risk Tolerance Dashboard, Experience with ERM Implementation—Initial Stocktake and Way Forward, Annual Fund Risk Report).

### Implementation status of ISR workstreams
- Nine workstreams identified; six prioritized for CY2023, two scheduled for CY2024.
- Of six scheduled for CY2023:
  - Work concluded for modifications to the DRS employment framework.
  - Significant progress made on other CY2023 workstreams.
- Budget implications partially addressed in FY2024; additional needs considered in FY2025 budget cycle.

### Tabled workstream highlights (status and timelines as in source)
- Workstream 1 — Board Ethics Committee—Review of the Board Code of Conduct (EP#1): Comprehensive report near finalization; Recommendations expected for Board consideration in the first half of CY2024.
- Workstream 2 — Task team on culture change (EP#30): OCC Task Team commenced February 2023; focus groups completed; draft proposal under review; formal proposal expected December 2023 and considered as part of FY25 budget discussions.
- Workstream 3 — Task Team to improve Grievance Committee process (EP#39): Benchmarking completed; draft memorandum issued November 2023; completion extends into first half of CY2024.
- Workstream 4 — HRD proposal to restructure HRD Employment Practices (EP#32): Draft proposal formulated; expected finalization in Q1 of CY2024 and consideration in FY25 budget discussions.
- Workstream 5 — Task team to develop a Whistleblower Policy (EP#8 (iv)): Existing protections embedded in rules; new standalone Whistleblower Policy expected finalized in Q1/Q2 of CY2024.

### Workstream prioritization and adjustments
- Some planned CY2024 actions/workstreams reprioritized or dropped based on implementation findings, sequencing needs, interlinkages, impact, and staff bandwidth.
- Three ISR actions (EP#10B, 10#C, 10#D) covering: (i) toolkit for self-represented employees; (ii) “real-time” case tracker; and (iii) posting additional information on the DRS webpage — are no longer deemed necessary and no further action is envisaged.
- Adjustments to estimated timelines reflected in the Annex; staff will refine estimates as work continues in CY2024.

### Next steps and embedding change
- Implementation remains resource-intensive for HRD and LEG; continued prioritization required in CY2024.
- Increasing emphasis on mainstreaming and operationalizing policy, process, and accountability changes to shape organizational culture improvements.
- Monitoring will use SES baseline, targeted pulse surveys, risk culture surveys, and OIA reviews to gauge impact.
- Management committed to open information sharing on ISR implementation via ISR intranet webpage, including an “Action Tracker”.

### Independent validation and reporting
- OIA to conduct an independent follow-up of ISR implementation in CY2024, likely commencing in the first half of CY2024.
- OIA assessment will provide an independent opinion on completed actions and report on in-train workstreams to flag implementation concerns.
- Future ISR implementation updates to the Board will leverage independent annual progress reporting by OIA (in lieu of staff updates), consistent with reporting on Board-endorsed IEO recommendations through OIA’s PMRs.

*Source: ppea2023060 - 23.      Important steps have been taken to strengthen institutional accountability and oversight mechanisms.*

### ANNEX I — ISR Action Tracker (selected entries and status)
- EP1 / EP8 (Managing Director ethical framework): Comprehensive review near finalization; Revised target date - Q1/Q2 of CY2024.
- EP2: Framework for publication of summary financial interests of Fund Management finalized; First summary statements to be published by the close of CY2023. CY2023 Q2/Q3 — Substantially completed; summary statements to be published in Q4 of CY2023.
- EP9A: First Summary Report on matters considered by Ethics Committee issued in CY22 Q4 — Completed.
- EP3A: OED access to informal DRS mechanisms approved June 2023. CY2023 Q2 — Completed.
- EP8(iii) and EP8(iv): Retaliation Policy updates incorporated in Staff Handbook updates and published in June 2023. CY2023 Q1/Q2 — Completed.
- EP8(vii): Extend period for access to Independent Review (IR) to three years being considered; Revised target date - Q1/Q2 of CY2024.
- Action 21 (Whistleblower Policy): Preliminary draft advanced; Revised target date - Q1/Q2 of CY2024.
- EP12: OII no longer requires authorization from Management or HRD before investigating cases; Staff Handbook updated end-June 2023. CY2023 Q1/Q2 — Completed.
- EP15A: OIA’s Charter amended to require EAC approval of OIA’s annual Program of Work. CY2023 Q1/Q2 — Completed.
- EP16A / EP16B / EP16C: ERM Policy approved December 2022 and Risk Tolerance framework in March 2023; OIA budget increases secured for FY23 and FY24; OIA triage exercise completed. CY2024 Q1/Q2 — On track / Ongoing as applicable.
- EP41/43: DRS/Ethics/Investigation Offices received structural percentage increase of 24.6 percent for FY24 and about 47 percent including transitional funds; DRS resourcing increased overall about 80 percent since FY22. CY2023 Q2 — Completed.
- EP39 (re-branding GC): Benchmarking completed; draft memorandum circulated November 2023; Revised target date – Q2 of CY2024.
- DAI 3: Interim guidance note issued April 2023 to ensure evenhanded coverage of emerging areas in surveillance. CY2023 Q1 — Completed.
- DAI 4A: Guidance expanding use of e-Review system issued. CY2023 Q1 — Completed.
- DAI 4B: Work on CRS as part of IDW commencement; OIA benchmarking exercise ongoing — Action not due until after rollout of IDW.
- EP10B / EP10C / EP10D: Tool-kit, real-time case tracker, and additional DRS case data not prioritized; No further action envisaged for EP10B and EP10C; EP10D — No further action envisaged.

### 2023 — Administrative Review Intake Form and related actions
- EP40: Standardized online Administrative Review Intake Form and Exit Questionnaire rolled out by HRD.
  - Timeline and status: CY2023 Q1 — Completed.
- EP41: Reinstatement and comparable position for wrongfully terminated employees — Work deferred and planned to be initiated in CY2024. CY2023 Q4 — Status: Delayed. Revised target date – Q3 of CY2024.
- EP42: Access to dispute resolution for contractual employees — Work planned to be deferred and initiated in latter part of CY2024; CY2024 Q4 — Status: Action Not Due.

*INTERNATIONAL MONETARY FUND — Annex I. ISR Action Tracker*

*Source: ppea2023060*

### EXECUTIVE SUMMARY

### EXECUTIVE SUMMARY

### Overall implementation progress
- The Institutional Safeguards Review (ISR) was completed and discussed by the Executive Board in June 2022.
- A Board-endorsed Implementation Plan (IP) was developed and discussed by the Board in December 2022 to address ISR recommendations and to foster a culture recognizing discourse and dissent as critical to the Fund’s mandate.
- The IP comprised 70 in-train or planned actions tracked through a consolidated “Action Tracker”.
- Substantial progress on actions targeted for completion in CY2023: 85 percent of the actions having been completed or remaining on track for completion by end of CY2023.
- Some actions were defined for implementation in CY2024; as IP implementation approaches the completion of a full year following Board endorsement, efforts to complete pending CY2023 actions remain broadly on track.

### Implementation monitoring and validation
- The IP set responsibilities, timelines, and a monitoring framework, with actions grouped under four key themes: (i) Data Analysis and Integrity; (ii) Leadership: Tone from the Top; (iii) Building Trust in and Strengthening DRS, Ethics, and Investigation Offices; and (iv) Oversight and Accountability.
- An ISR Program Lead was appointed to coordinate implementation, track completion, and support progress reporting.
- The Action Tracker aligns with Management Implementation Plan (MIP) Board reporting practice and was used for periodic status update discussions.
- The Office of Internal Audit (OIA) will conduct an independent assessment of ISR implementation in CY2024, consistent with OIA’s Periodic Monitoring Reports (PMRs).

### Data analysis and integrity — actions and status
- The IP contained four recommendations to strengthen data analysis and integrity: (#1A) clarify and formalize terms of engagement of OEDs in staff’s conduct of analysis; (#1B) explore mechanisms for staff to raise concerns about undue influence; (#2) clarify Management’s role in the internal clearance process; (#3) ensure evenhanded coverage of emerging areas; (#4A) improve transparency and documentation of the internal review process; (#4B) assess adaptation of the review process to the CRS rollout as part of the IDW program.
- All recommendations to further protect and strengthen data analysis and integrity (with the exceptions of #1B and #4B) have been fully actioned through the issuance of specific guidance.
- A joint note clarifying terms of engagement between Offices of Executive Directors (OED) and staff was issued in June 2023; the staff guidance was issued by Management and relevant sections applicable to OEDs were concurrently approved by the Executive Board.
- The joint note clarifies expectations for interactions between staff and OEDs across surveillance, lending, capacity development, corporate and support functions, and applies to engagements in the field and at headquarters.
- The guidance seeks to protect staff analysis from undue influence and requires close monitoring by first-line departments and reinforcement through institutional review/enforcement mechanisms.

### Leadership, ethics, and tone from the top — key measures
- The summary statement on the Board Ethics Committee’s activities was published for all staff for the first time in November 2022.
- A regular schedule of ethics training for all OED personnel was introduced; the first session was delivered in Q1 of CY2023.
- The Executive Board approved a proposal to provide all OED personnel access to the Fund's Ombuds and Mediation offices.
- Work is progressing on reviewing the Board’s Code of Conduct and the ethical framework applicable to the Managing Director; final recommendations are expected to be tabled for Board consideration in the first half of CY2024.
- The framework for publication of summary financial statements and interests of the Managing Director and the Deputy Managing Directors has been finalized, with the first summary statements to be published on the Fund’s external website by the close of CY2023.

### Building trust in and strengthening DRS, Ethics, and Investigation Offices
- IP actions aim to shift the focus toward prevention and early, informal resolution while streamlining formal DRS processes.
- Greater access to results from DRS Offices has been advanced through: (i) a joint meeting between Management and the DRS, Ethics, and Investigation Offices; and (ii) a Management-chaired informal Board briefing to discuss activities and respective Annual Reports of these Offices.
- The Executive Board approved changes to the DRS Employment Framework in June 2023 to bring these roles into closer alignment with comparator IFI organizations.
- Implementation of the FY24 workforce planning exercise for the DRS, Ethics, and Investigation Offices resulted in a significant increase in structural budget and staffing for these Offices.
- Policy proposals to implement changes to the Retaliation Policy and misconduct procedures are reflected in recent Staff Handbook updates.
- Development of a Whistleblower Policy is proceeding and is expected to be finalized in Q1/Q2 of CY2024.
- Additional workstreams launched include: identifying root causes and drivers for culture change, streamlining Grievance Committee procedures, and strengthening the employee relations function in HRD.

### Oversight, accountability, and enterprise risk management
- OIA’s Charter was amended to require the External Audit Committee (EAC) to approve OIA’s annual Program of Work; the EAC formally approved OIA’s FY24 Program of Work.
- Key building blocks for ERM operationalization have been put in place: Board approval of the ERM Policy in December 2022 and the Risk Tolerance (RT) framework in March 2023.
- ORM has made commendable progress actioning the 2021 audit recommendations, with a majority of the actions validated and closed by OIA.
- Progress in actioning prior audit recommendations and in strengthening oversight mechanisms supports institutional accountability and independence.

### Culture, measurement, and next steps
- The 2022 Staff Engagement Survey (SES) provided a benchmark on staff sentiment around staff voice and trust and will inform continued work on institutional culture.
- The monitoring framework will use targeted staff pulse surveys, risk culture surveys, and OIA assessments of ISR progress to gauge impact over time.
- Mainstreaming and operationalizing policy, process, and accountability changes will be a growing focus as implementation approaches a full year.
- Management commits to open and transparent information sharing on ISR implementation resources via the ISR intranet webpage, including an “Action Tracker” providing a current accounting of implementation status for each IP action item.

*Prepared by the ISR implementation core group; update as of December 1, 2023.*

### Box 1. Shared Principles Underpinning Terms of Engagement between OEDs and Fund Staff

### Box 1. Shared Principles Underpinning Terms of Engagement between OEDs and Fund Staff

### Shared principles
- Continuous and candid dialog: Continuous and candid dialog between staff, OEDs, and national authorities at various stages of staff analysis is vital to the efficient and effective conduct of the Fund’s business.
- Independence of staff technical analysis and policy advice: Staff should pay due regard to OEDs’ and national authorities’ views, inputs, and arguments but must not be subjected to undue influence to alter their conclusions against their best professional judgment and relevant Fund rules and policies.
- Mutual respect and professional courtesy: Regardless of their role or position, all Fund personnel (OEDs, staff, and Management) are expected to conduct themselves with the highest standards of professional integrity and to treat others with professional courtesy and respect.

### Management role, guidance, and documentation
- February 2023 guidelines clarify Management’s role in clearance of staff reports:
  - Management decisions are to be taken on the basis of staff analysis and advice, while Management retains prerogative to provide guidance on staff work and to exercise judgment on strategic issues within the Articles of Agreement and Board-approved policies.
  - Authoring and reviewing departments are expected to bridge differences through dialog to limit Management arbitration to strategic issues.
  - Departments should not be discouraged from seeking Management arbitration when appropriate; disagreements and Management arbitration are part of healthy internal debate and dissemination.
  - Management decisions are communicated in writing with explanations of considerations motivating the decision when resolving disagreements.
  - Authoring departments should present: (i) a concise and objective summary of issues requiring Management attention and decision; (ii) a candid presentation of issues raised in the review process; and (iii) a discussion of potentially controversial issues and implications of Management’s decision options.

### Surveillance of emerging priority areas
- April 2023 interim guidance instructs staff to take an evenhanded approach to surveillance of emerging priority areas, including climate, digital money, gender, and to some extent inclusion issues, consistent with Board-approved strategies.
- Operational guidance will evolve; in-depth coverage where the Fund is still building capacity will be achieved over the medium-term for members where topics are macro-critical.
- Where capacity limitations impede upfront in-depth coverage, country teams should develop a plan to cover the issue in depth over the medium-term.
- Time horizon for coverage should match associated macroeconomic risks; country teams must balance coverage against other urgent priorities.
- Given resource constraints, in the short-term some countries will have had a deep dive analysis of a macro-critical area while some countries will have discussed these issues in a lighter way.

### Interdepartmental review process and Common Review System (CRS)
- Guidance expands documents using the e-Review system for interdepartmental review and Management clearance.
- Work has commenced on designing and implementing a Common Review System (CRS) to enable a more comprehensive, transparent, auditable, and traceable review process and accommodate future changes in review policies.
- OIA is concluding a benchmarking exercise of the Fund’s review process to inform assessment of how the review process will adapt to the rollout of the CRS (#4B).

### Mechanisms to raise concerns of undue influence and related protections
- Terms of reference of the Ombudsperson and the Office of Mediation were amended to make explicit authority to help staff address concerns of undue influence.
- Work is underway on development of a Whistleblower Policy to provide further protection for staff raising concerns through appropriate channels.
- All Fund personnel have access to the full range of informal dispute resolution mechanisms and the Ethics and Investigation offices to raise concerns about undue influence.
- Further opportunities to leverage existing avenues (such as the Ethics Office) to help staff address concerns of undue influence are being identified.
- Finalization of the proposal has been deliberately deferred to follow work on Recommendation #1A (clarifying terms of engagement between OED and staff) and to permit completion of amendments to the Terms of Reference for the Ombudsperson and the Office of Mediation, and to take on board the Whistleblower Policy work.
- Finalization of the proposal is expected in Q1/Q2 of CY2024.
- Note: The Office of Internal Investigations (OII) does not have jurisdiction over Offices of Executive Directors (OED) and their staff; raising concerns about undue influence would only apply for Fund staff/employees.

### Leadership, tone from the top, and ethics transparency
- Actions completed or progressing to demonstrate Board and Management commitment to ethical conduct, transparency, and cultural change:
  - Summary statement on the Board Ethics Committee’s activities published for all staff for the first time in November 2022.
  - Regular schedule of ethics training introduced for all OED personnel; first session delivered in Q1 of CY2023.
  - Review of the Board’s Code of Conduct and ethical framework applicable to the Managing Director is underway; final recommendations expected to be tabled for Board consideration in the first half of CY2024.
  - Executive Board approved proposal to provide all OED personnel access to the Fund's Ombuds and Mediation offices.
  - Framework for publication of summary financial statements and interests of the Managing Director and the Deputy Managing Directors has been finalized; first summary statements to be published on the Fund’s external website by the close of CY2023.

### Access to Ombuds and Mediation offices for OED personnel
- In June 2023 the Executive Board approved granting all OED personnel access to the Ombuds and Mediation offices on the same basis as Fund staff.
- This access enables OED personnel to seek guidance in a voluntary, informal, and confidential setting.
- Approval does not alter provisions of the OED employment framework, including the discretion of Executive Directors on appointment and termination decisions regarding personnel.
- The Managing Director remains authorized to amend Terms of Reference of these offices as they pertain to staff, with the Board informed accordingly.
- The annual session to brief the Board, with Management and relevant Heads of DRS, Ethics, and Investigation Offices, has been and will continue to be leveraged to allow Executive Directors to ask questions on broad issues concerning OED matters.

### Publication of financial summaries for leadership
- Ethics Committee proposed, and the Board agreed, that current and future Managing Directors should be subject to publication requirements adopted by the Managing Director for the Deputy Managing Directors.
- Per the finalized framework, the first summary statements of the Managing Director and the Deputy Managing Director will be published on the Fund’s external website by the close of CY2023.
- The summaries will be posted for the duration of the Managing Director’s tenure plus a further period of two years (six months for the Deputy Managing Directors), consistent with the “cooling off” period for terms of appointment of the Managing Director/Deputy Managing Directors.
- Thereafter, summaries would be removed from the Fund’s website but deemed a record of the Fund and treated as “other documentary material” under the Fund’s Open Archives Policy.

### Building trust in and strengthening DRS, Ethics, and Investigation Offices
- IP actions aimed to foster staff trust and confidence in the DRS system and ensure protection of staff voice and consistent, fair application of disciplinary and misconduct processes without fear of reprisal; actions included:
  - Revising the employment framework for DRS Offices.
  - Enhancing accessibility of DRS channels and offices.
  - Improving transparency on case processing and outcomes.
  - Addressing delays and clearing specific backlogs as appropriate (cases/annual reports).
  - Reviewing adequacy of resources within a resource-constrained environment.
- Core focus shifted toward prevention and early, informal resolution of disputes while streamlining and improving formal DRS channels.

### Employment framework changes for DRS, Ethics, and Investigation Offices
- Executive Board approved changes in June 2023 comprising two components:
  - Hiring of future heads of DRS, Ethics, and Investigation Offices (Ombuds, Mediator, Ethics Advisor, and Head, OII) on a staff term appointment with an initial term of 3 years and the possibility of one renewal for an additional period of six years (for a total period of 9 years), without the prospect of open-ended employment.
  - Following provision of additional FTE resources for such offices, eliminating the exemption for contractual employees in the DRS, Ethics, and Investigation Offices (including contractual employees in the Grievance Committee and the Administrative Tribunal) from the four-year maximum under the current Categories of Employment (CoE) framework—to allow for a balance of longer-term and temporary and rotational positions similar to other Departments.
- These CoE changes were informed by institutional needs and aim to align practices with comparator organizations while preserving and strengthening independence and impartiality of these offices.
- Changes have been communicated to relevant staff through townhalls and briefings and are being operationalized.

### Workforce planning and resourcing for DRS, Ethics, and Investigation Offices
- Completion and implementation of the workforce planning exercise for FY24 for the DRS, Ethics, and Investigation Offices is critical to augmenting resourcing and strengthening organizational positioning and independence.
- Resourcing changes and increases:
  - DRS, Ethics, and Investigation Offices collectively received the largest structural percentage increase in the Fund (24.6 percent) for FY24 budget allocations and about 47 percent after including transitional funds.
  - This builds on an overall 30 percent increase in DRS resourcing allocated to the Offices in FY23, with an overall upward shift in resources since FY2022 of about 80 percent.

### Structured engagement, thematic briefings, and forward-looking considerations
- Structured engagement established between DRS, Ethics, and Investigation Offices, Management, and the Board:
  - Joint meeting between Management and the DRS, Ethics and Investigation Offices.
  - Management-chaired informal Board briefing (June 2023) to discuss activities and Annual Reports of these Offices and to take stock of thematic issues and systemic/cross-cutting trends.
- Forward-looking considerations highlighted:
  - Build organizational muscle for staff to engage in open conversations and respectfully disagree and to examine underlying root causes amid rising caseloads.
  - Focus more on conflict prevention and developing toolkits for staff and managers (training and coaching programs), an area of focus for the Mediation Office.
  - Enable lasting behavioral changes requiring concerted action and change management efforts by the DRS Offices.
  - Proactive communication by DRS, Ethics, and Investigation Offices of mandatory obligations of staff and managers will be key so staff can leverage training, outreach, and attestation.

### Staff Handbook updates and procedural changes
- Updates to the Staff Handbook completed, including adjustments to misconduct and disciplinary procedures and the Retaliation Policy to support greater autonomy of relevant DRS Offices, including:
  - Clarifying duty of care to individuals reporting suspected retaliation by requiring Managers and supervisors to report suspected misconduct to the Office of Internal Investigations (OII).
  - Removing requirement for OII to obtain authorization from the HRD Director or Management to initiate a formal investigation (OII will continue to report to Management regarding matters that, in its judgment, merit such communication to address operational or other risks, actual or perceived conflicts of interest, or to recommend interim or protective measures).
  - Establishing OII as the centralized entry point of any misconduct allegation so OII can serve as focal point to re-route for appropriate action.
  - Incorporating express reference to proactive intervention by OII when interim protective measures are identified—proactive interim protective measures for complainants or witnesses of alleged retaliation will help protect users of the DRS, Ethics, and Investigation Offices against adverse action for using the system.
- These revisions will be supported by targeted training for managers, Resident Representatives, and HR Teams, and incorporated into Ethics Office training programs, OII’s outreach program, and other communications initiatives.

### Access to information and disclosure improvements
- Considerable progress made to enable greater and timelier access to information about work and outcomes of DRS, Ethics, and Investigation Offices:
  - Delays in issuance of Annual Reports prior to CY2022 have been remediated; Annual Reports for CY2022 have now been issued by the Ethics Office, Ombuds Office, Mediation Office, Office of Internal Investigations, the Administrative Review function, and the Grievance Committee.
  - Grievance Committee completed publication of redacted copies of its recommendations (since 2018) to its intranet site.
  - OII Annual Report disclosures have been augmented to provide summaries of cases addressed and outcomes, balanced with confidentiality considerations.
  - Awareness-building activities (Townhalls and “Open House” events) are being undertaken regularly; most recent DRS Townhall convened in November 2023.
  - Actions implemented to make dispute resolution process more accessible, including rollout by HRD of a standardized online Administrative Review Intake Form and an Exit Questionnaire to aid case tracking and systematic follow-up.

*Source: ppea2023060 - Box 1. Shared Principles Underpinning Terms of Engagement between OEDs and Fund Staff*

### 23.      Important steps have been taken to strengthen institutional accountability and

### 23.      Important steps have been taken to strengthen institutional accountability and 

### Strengthening institutional accountability and oversight
- Measures taken include:
  - (i) expand on safeguards to preserve the independence of the Office of Internal Audit (OIA);
  - (ii) enable systematic monitoring of the remediation of open OIA and IEO recommendations; and
  - (iii) advance the ongoing work to support the implementation of the “3 Lines” Model and strengthen the Fund’s Enterprise Risk Management (ERM) capabilities and processes.

### OIA independence, governance, and resourcing
- OIA’s Charter amended to include an additional step requiring the External Audit Committee (EAC) to approve OIA’s annual Program of Work.
  - Change intended to respond to the ISR recommendation to enhance OIA’s independence.
  - EAC has formally approved OIA’s FY24 Program of Work.
- OIA capacity and budgetary actions:
  - OIA secured increases in its structural budget envelope in FY2023 and additional transitional resources in FY2024.
  - The annual budget cycle and accountability framework discussion with Management will continue as the mechanism for evaluating OIA’s resource adequacy.
  - The OIA Director can flag resource adequacy issues to the External Audit Committee after exhausting internal procedures.

### Monitoring and remediation of OIA and IEO recommendations
- FY2023 triage exercise:
  - OIA completed a triage exercise to give departments an accurate view of open audit issues and facilitate risk mitigation.
  - The triage was endorsed by the Fund Risk Committee and the External Audit Committee.
  - Departments with significant progress in closing overdue actions include HRD, ITD, and CSF.
- Primary reasons for implementation delays identified:
  - (i) competing work priorities within a resource-constrained environment, particularly in the context of the pandemic and the Fund’s crisis response focus;
  - (ii) operational/implementation challenges.
- Departmental responses:
  - Departments provided revised target dates for implementing action plans for overdue audit issues and committed to proactively review progress.
  - OIA will support departments through improved departmental partnership (nomination of departmental key contacts) and issuance of guidance on expectations for formal action plans and revised target dates.
- IEO monitoring:
  - OIA’s Thirteenth Periodic Monitoring Report (PMR) was discussed with the Board in November 2023.

### ERM operationalization and risk processes
- Board approvals:
  - ERM Policy approved in December 2022.
  - Risk Tolerance (RT) framework approved in March 2023.
- Scope and roles:
  - ERM Policy states all Fund activities are within ERM scope (surveillance, lending, CD, administrative and support functions).
  - Policy strengthens the role of ORM to provide an “independent view and challenge” of enterprise risk management work and reporting by Departments.
- Departmental ERM activities:
  - Risk and Control Self Assessments (RCSAs), Document Risk Self Assessments (DRSAs), Risk Event Reporting, Risk Treatments, and adherence to the new Risk Tolerance framework are being undertaken.
  - Most departments have completed at least one pilot RCSA of core business processes.
  - CSF implemented a thorough third-party risk assessment during procurement and is progressing toward a comprehensive Third-Party Risk Management (TPRM) process to enable monitoring throughout a vendor’s engagement.
  - Some DRSAs of key policy, strategy, administrative and country papers have been prepared.
- ORM audit recommendations:
  - ORM has made progress actioning the 2021 audit recommendations, with a majority of actions validated and closed by OIA.
- Board briefings and reporting:
  - The Board will be briefed/informed on specific areas (Risk Tolerance Dashboard, Experience with ERM Implementation—Initial Stocktake and Way Forward, Annual Fund Risk Report) through upcoming engagement checkpoints.

### Implementation status of ISR workstreams
- Nine workstreams were identified; prioritization critical due to staff workload and complexity.
- Six workstreams prioritized for implementation in CY2023, with two others scheduled for CY2024.
- Of the six scheduled for CY2023:
  - Work concluded for modifications to the DRS employment framework.
  - Significant progress made on remaining workstreams planned for CY2023.
- Budget implications:
  - Partially addressed in FY2024, with consideration of additional needs in the context of the FY2025 budget cycle underway and future budget cycles.

- Tabled workstream highlights (implementation status and timelines preserved as in source):
  - Workstream 1 — Board Ethics Committee—Review of the Board Code of Conduct (EP#1)
    - Stakeholder: Ethics Committee
    - Status: Comprehensive report near finalization following benchmarking and consultations. Recommendations expected to be tabled for Board consideration in the first half of CY2024.
  - Workstream 2 — Task team on culture change (EP#30)
    - Stakeholders: HRD, COM
    - Status: Organizational Culture Change (OCC) Task Team commenced February 2023; focus group sessions completed; draft proposal under review; formal proposal to Management expected December 2023 and considered as part of FY25 budget discussions.
  - Workstream 3 — Task Team to improve Grievance Committee process (EP#39)
    - Stakeholders: Grievance Committee Chair, HRD, LEG, SAC
    - Status: Benchmarking completed; draft memorandum to Management issued in November 2023; completion extends into first half of CY2024.
  - Workstream 4 — HRD proposal to restructure HRD Employment Practices (EP#32)
    - Stakeholder: HRD
    - Status: Draft proposal formulated; expected finalization in Q1 of CY2024 and consideration as part of FY25 budget discussions.
  - Workstream 5 — Task team to develop a Whistleblower Policy (EP#8 (iv))
    - Stakeholders: OII, LEG, HRD, ETO, SAC
    - Status: Existing protections embedded in rules; new standalone Whistleblower Policy expected finalized in Q1/Q2 of CY2024 to define terms, responsibilities, and codify protections.

- Workstream prioritization and adjustments:
  - Some planned CY2024 actions/workstreams are being reprioritized or dropped given implementation findings, sequencing needs, interlinkages, impact, and staff bandwidth.
  - Three ISR actions (EP#10B, 10#C, 10#D) covering: (i) creation of a toolkit for self-represented employees; (ii) requiring a ”real-time” case tracker; and (iii) posting additional information on the DRS webpage — are no longer deemed necessary and no further action is envisaged.
  - Adjustments to estimated timelines reflected in the Annex; staff will refine estimates as work continues in CY2024.

### Next steps and embedding change
- Resource intensity and prioritization:
  - Implementation efforts have been resource-intensive for HRD and LEG leading several ISR actions and workstreams; this will continue in CY2024 requiring significant prioritization.
- Focus shift as implementation moves into CY2024:
  - Increasing emphasis on mainstreaming and operationalizing policy, process, and accountability changes introduced by the IP actions to shape organizational culture improvements.
- Monitoring and evidence:
  - Results of the 2022 Staff Engagement Survey (SES) used as a benchmark on staff voice and trust.
  - Monitoring framework will leverage targeted staff pulse surveys, risk culture surveys, and OIA reviews over time to gauge impact of completed ISR actions.
- Communication and transparency:
  - Management committed to open and transparent information sharing on the ISR implementation journey.
  - Relevant information and resources posted on the ISR intranet webpage, including an “Action Tracker” providing a current and full accounting of implementation status for each action item.

### Independent validation and reporting
- OIA independent follow-up:
  - OIA will conduct an independent follow-up of ISR implementation in CY2024.
  - The OIA assessment will provide an independent and objective opinion on completed actions and report on in-train workstreams and actions to flag implementation concerns.
  - Timing: assessment likely to commence in the first half of CY2024.
  - Future ISR implementation updates to the Board will leverage independent annual progress reporting by OIA (in lieu of staff updates), consistent with reporting on Board-endorsed IEO recommendations through OIA’s PMRs.

*Source: ppea2023060 - 23.      Important steps have been taken to strengthen institutional accountability and oversight mechanisms.*

### Annex I. ISR Action T

### Annex I. ISR Action Tracker

### Governance, Ethics, and Board Code of Conduct
- EP1 / EP8 (Managing Director ethical framework): Comprehensive review of the Board Code of Conduct and the Managing Director’s ethical framework is near finalization; recommendations to be tabled for Board consideration. Original target CY2023 Q2/Q3. Status: Delayed. Revised target date - Q1/Q2 of CY2024.
- EP2: Framework for publication of summary financial interests of Fund Management finalized. First summary statements to be published on the Fund’s external website by the close of CY2023. CY2023 Q2/Q3 — Substantially completed; summary statements to be published in Q4 of CY2023.
- EP9A: First Summary Report on number and nature of matters considered by Ethics Committee issued in CY 22 Q4. CY2022 Q4 — Completed. Report to be issued at the end of each Ethics Committee’s term going forward.
- EP21 / EP22 / EP23: Board engagement on ethics transparency being advanced through Steering Group and review of Board Code of Conduct; internal Executive Board meeting and Board-level transparency initiatives underway. CY2023 Q1/Q2 — Partially completed / Ongoing; review planned for Q1/Q2 of CY2024.
- EP29 / EP31: Training and outreach to employees to engage with DRS, Ethics, Ombudsperson; “Giving Voice to Values” campaign and PRW training modules implemented. Ongoing.

### Dispute Resolution Systems (DRS), Retaliation, and Whistleblower Protections
- EP3A: OED access to informal DRS mechanisms approved by Executive Board in June 2023. CY2023 Q2 — Completed.
- EP3B: OED access to formal DRS to be considered by CAM after experience with informal access. Revisit end-CY2024 — Action not due.
- EP5: Proposal that Secretariat of Ethics Committee be an external lawyer to be considered as part of full review of Board Code of Conduct. Revisit after review of Board’s Code of Conduct — Action not due.
- EP8(ii) / EP8(iii) / EP8(iv) / EP8(v) / EP8(vi) / EP8(vii) / EP8(viii) / EP8(ix):
  - EP8(iii) and EP8(iv): Necessary updates to Retaliation Policy incorporated in Staff Handbook updates and published in June 2023. CY2023 Q1/Q2 — Completed.
  - EP8(v) and EP8(vi): Retaliation Policy updates incorporating affirmative supervisory responsibility and investigator obligations incorporated in Staff Handbook updates published in June 2023. CY2023 Q1/Q2 — Completed.
  - EP8(ii): Decisions on performance consequences for retaliatory actions made by Responsible Official based on OII Investigation Report. Ongoing.
  - EP8(vii): Extend period for access to Independent Review (IR) to three years being considered as part of Whistleblower Policy work. CY2023 Q4 — Delayed; Revised target date - Q1/Q2 of CY2024.
  - EP8(viii): Staff Engagement Survey (SES) included relevant questions to set baseline. CY2023 Q1 — Completed. Follow-up Pulse Surveys planned after 2 years of the SES. End-CY2024 — Action Not Due.
  - EP8(ix): ToRs of Ombuds and Mediation Office amended to explicitly consider allegations of undue influence; approved by Management in July 2023. CY2022 Q4 — Completed.
- Action 21 (Whistleblower Policy): Preliminary draft advanced, informed by benchmarking; expected to define terms, responsibilities, and protections. CY2023 Q4 — Delayed given need for extensive stakeholder consultations and impending leadership transition in OII. Revised target date - Q1/Q2 of CY2024.
- Action 18 / 19 / 20 (Awareness and communications): Multiple awareness events and townhalls held (DRS Open House December 2022; “Meet your Ombudsperson”; SAC-facilitated DRS Townhall November 2023). CY2023 Q1/Q2 — Completed. Ongoing communications and FUNDALL updates continue.

### Office of Internal Investigation (OII), Office of Independent Audit (OIA), and Oversight
- EP12: OII no longer requires authorization from Management or HRD before investigating cases; changes incorporated in Staff Handbook updates (end-June 2023). CY2023 Q1/Q2 — Completed.
- EP13: Investigations centralized and conducted by OII only; OII established as centralized entry point and Staff Handbook updated. CY2023 Q1/Q2 — Completed.
- EP15A: OIA’s Charter amended to require External Audit Committee (EAC) approval of OIA’s annual Program of Work. CY2023 Q1/Q2 — Completed (EAC approved OIA’s FY24 Program of Work).
- EP16A / EP16B / EP16C:
  - EP16A: ERM Policy approved December 2022 and Risk Tolerance framework in March 2023; ORM progressing on 2021 audit recommendations. CY2024 Q1/Q2 — On track for completion.
  - EP16B: OIA secured increases in structural budget envelope for FY23 and additional transition resources for FY24; annual budget cycle remains forum for evaluating OIA resources. Ongoing — Completed.
  - EP16C: OIA completed triage exercise to help departments manage open audit issues; IEO recommendation monitoring through OIA Periodic Monitoring Reports (Thirteenth PMR scheduled for Board discussion November 2023). Ongoing.
- EP41/43 (resourcing and monitoring): DRS/Ethics/Investigation Offices received structural percentage increase of 24.6% for FY24 and about 47% including transitional funds; DRS resourcing increased overall about 80 percent since FY22. CY2023 Q2 — Completed.

### Grievance Committee (GC), Administrative Review, and Administrative Tribunal (AT)
- EP17 / EP37 / EP36 / EP39:
  - EP39 (re-branding GC): Benchmarking completed; options for redesign explored; draft memorandum circulated to Management in November (CY2023 Q4 target). CY2023 Q4 — Delayed due to need for extensive stakeholder consultations. Revised target date – Q2 of CY2024.
  - EP36 / EP37: Changes to Administrative Review (mandatory first step for benefits disputes; optional for other cases) and enforcement of short timelines planned; Task Team work planned to start in second half of CY2024. CY2024 Q4 — Action Not Due.
  - EP17: Efforts to streamline and improve GC process linked to EP39; CY2023 Q4 — On track for completion (workstream established).
- EP34: LEG’s memorandum reporting on Administrative Tribunal decisions issued July 2023 with a “Lessons Learned” section. Ongoing — Completed; to continue annually.
- EP31 / EP35: Development of Staff Legal Counsel (SLC) function deferred to Q1 CY2024 to leverage GC streamlining outcomes; draft proposals expected by Q2 CY2024. CY2023 Q4 — Delayed.

### Internal Review Processes, Documentation, and Digital Tools
- DAI 3: Interim guidance note issued to staff in April 2023 to ensure evenhanded coverage of emerging areas in surveillance. CY2023 Q1 — Completed.
- DAI 4A: Guidance issued expanding use of e-Review system for interdepartmental review and Management clearance. CY2023 Q1 — Completed.
- DAI 4B: Work commenced to design and implement a Common Review System (CRS) as part of Integrated Digital Workplace (IDW); OIA concluding benchmarking exercise to inform CRS implementation. After rollout of IDW — Action not due.
- EP10A / EP10B / EP10C / EP10D (DRS intranet, toolkit, case-tracker, case data):
  - EP10A: DRS intranet page updated on ongoing basis. Ongoing — Ongoing.
  - EP10B / EP10C / EP10D: Work on a self-represented employee Tool-Kit and real-time case tracker not prioritized; consensus that existing internal tracking mechanisms suffice. CY2024 Q2/3 and CY2024 Q3 and CY2025 — No further action is envisaged for 10B and 10C; EP10D — No further action is envisaged.

### Culture Change, Management Training, and Accountability
- EP6 / EP7 / EP19 / EP20 / EP24A / EP24B / EP25 / EP26 / EP27-28 / EP30:
  - EP30 (Organizational Culture Change - OCC): OCC Task Team formed February 2023; inventory and focus groups completed June/July 2023; draft proposal under review with formal proposal expected December 2023 for FY25 budget discussions. CY2023 Q4 — On track for completion.
  - EP6: Townhall held February 2023 and FUNDALL updates; SAC-facilitated DRS Townhall in November 2023. From CY22 Q4 onwards — Ongoing.
  - EP7 / EP14 / EP18 / EP19: Actions to ensure consistent penalties, Board/Management leadership on culture, and substantive OII reporting implemented; OII Annual Reports for 2021 and 2022 issued May 2023 included more substantive summaries. Ongoing.
  - EP24A: Interim protective measures implemented; whistleblower policy work to codify protections including complainant reassignment protections. Planned for completion Q2 of CY2024.
  - EP24B: Existing Retaliation Policy provides protection to employees who use DRS; remedial action if retaliation established. Ongoing.
  - EP25: Guidance to record peer-review/GC contributions in APR updated for CY2023 APR cycle. CY2023 Q2 — Completed.
  - EP26 / EP27-28: Ongoing efforts to reflect accountability and collaborative problem-solving in performance reviews and manager development. Ongoing.
  - EP31: Ethics Office and Mediation will further strengthen training for Peers for a Respectful Workplace (PRWs); several modules launched in CY2023. Ongoing.
  - EP32: Proposal to establish Employee Relations Unit within HRD drafted; consultations ongoing with expected finalization and submission to Management in Q1 CY2024 and consideration in FY25 budget. CY2023 Q4 — Delayed; Revised target date Q1 of CY2024.

### Implementation Tracking and Next Steps
- Multiple actions completed in CY2023 Q1–Q2 and CY2022 Q4 (see entries marked Completed).
- Several initiatives delayed to Q1/Q2 of CY2024 or Q2 of CY2024 due to stakeholder consultations, workload, and leadership transitions (notably Board Code of Conduct finalization, Whistleblower Policy, GC redesign, Employee Relations Unit).
- Actions scheduled for CY2024 Q4 (Administrative Review procedural reforms and timelines) remain Action Not Due and will be initiated in second half of CY2024.
- Ongoing items include culture-change implementation, monitoring of OIA/IEO recommendation follow-up, continued communications/outreach, and maintenance of DRS/Ethics/Investigation resourcing and operations.

*INTERNATIONAL MONETARY FUND — Annex I. ISR Action T racker*

### 2023.  It is expected that the proposal will be

### ppea2023060 - 2023.  It is expected that the proposal will be

### Administrative Review Intake Form
- EP40: Create a form for filing requests for administrative review and include a section asking specifically for a description of the measures the complainant would like HR to take.
- Support: HRD has rolled out the completion of a standardized online Administrative Review Intake Form as well as an Exit Questionnaire.
- Timeline and status:
  - CY2023 Q1
  - Completed

### Reinstatement and comparable position for wrongfully terminated employees
- EP41: The Fund should devote greater efforts to offer a comparable position within the organization to an employee whose employment was wrongfully terminated.
- Proposed workplan:
  - A Task Team, comprising HRD, LEG, and SAC, will prepare a proposal for management approval.
  - The Task Team will consider a new Staff Handbook rule setting out a formal decision-making protocol for consideration of reinstatement in cases involving the end of employment.
- Support/status notes:
  - Support: This work is being deferred (given competing priorities) and is planned to be initiated in CY2024.
  - CY2023 Q4
  - Status: Delayed.
  - Revised target date – Q3 of CY2024.

### Access to dispute resolution for contractual employees
- EP42: All employees of the Fund (including contractual employees) should enjoy the same access to all the DRS and related offices, including the Grievance Committee and the Administrative Tribunal.
- Proposed workplan:
  - It is proposed that a WGs, led by a senior staff member designated by management, composed of representatives from HRD, LEG and SAC, including the Ombudsperson, would develop proposals for any amendments to the dispute resolution procedures applicable to contractual employees.
- Support/status notes:
  - Requires further consultation – workstream established.
  - This work is planned to be deferred and initiated in the latter part of CY2024 and will be informed by the lessons learned from the GC streamlining work.
  - CY2024 Q4
  - Status: Action Not Due

*INTERNATIONAL MONETARY FUND*

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_Source: https://www.imf.org/-/media/files/publications/pp/2023/english/ppea2023060.pdf_
