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Bretton Woods Observer Summer 2022
A quarterly critical review of developments at the World Bank and IMF

Published by BRETTON WOODS PROJECT
Working with NGOs and researchers to monitor the World Bank and IMF

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1. World Bank and IMF’s response to global food crisis misses mark,
as financial speculation drives food prices to historic highs
2. Why the IFC can’t afford to squander this opportunity to get
remedy right
By Robi Chacha Mosenda and Megan Pearson, Accountability Counsel
3. New IMF Resilience and Sustainability Trust (RST) – how to make it
work for the Global South
4. World Bank’s commitment to private sector-led development casts
doubt on effectiveness of new Pandemic Preparedness Fund
5. A new Bretton Woods for whom? Civil society calls for
democratisation of global governance
6. World Bank’s IFC ends funding for fee-paying primary and secondary
schools
7. What is the World Bank’s International Center for the Settlement
of Investment Disputes (ICSID)?
8. Highly indebted countries face further cuts to public spending to
service debts, as IMF austerity bites
9. The IMF is changing and needs an independent ombudsman
By Danny Bradlow, American University Washington College of Law
10. Mozambique IMF loan moves forward amid serious sustainability and
transparency concerns
11. Report on privatisation of Kenya’s healthcare highlights human
impact of World Bank’s private sector bias
12. Resilience and Sustainability Trust: Will “qualifying reforms”
bring long-overdue institutional shift?
13. World Bank’s new gender strategy: Concerns about approach to
social protection and gender-blind macroeconomic reforms remain
14. Restart of Pakistan’s IMF loan agreement collapses with change in
government, as soaring costs of IFC-supported LNG add to fiscal pain
15. IFC approves loan to industrial agriculture producer in Brazil
despite pleas for protection of sensitive grassland biome

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LAND/analysis

World Bank and IMF’s response to global food crisis misses mark, as
financial speculation drives food prices to historic highs

SUMMARY
- Rising food prices linked to rampant speculation in food futures
rather than ‘market fundamentals’, say experts
- World Bank and IMF’s emphasis on encouraging open trade of
agricultural goods and increasing production misdiagnoses root causes
of crisis
- Despite looming hunger in many African countries, World Bank warns
countries against introducing food subsidies

The world faces an acute food crisis, with food prices hitting all-
time highs in March, according to the UN Food and Agriculture
Organization, before receding in recent months.
Russia’s invasion of Ukraine has brought the issue into focus, as
both countries are key producers of grain exports and agricultural
fertilisers.
But while the Covid-19 pandemic and the conflict in Ukraine have
exacerbated issues in global agriculture supply chains, food experts
argue that the crisis is not rooted in a global food shortage, with
current food production sufficient to feed the world’s population 1.5
times over – but rather in an increasingly unequal and financialised
global food system.
As Professor Jennifer Clapp, vice-chair of the High Level Panel on
Food Security and Nutrition, argued in May on online platform Civil
Eats, “The [current] excessive price rises and fluctuations… are not
based on market fundamentals. In just nine days in March 2022, the
price of wheat on futures markets jumped 54 percent.…Evidence
suggests financial speculators are jumping into commodity investments
and gambling on rising food prices.”
According to Professor Sergio Leite of Universidade Federal Rural Rio
de Janeiro in Brazil, “the upward movement in prices begins in
mid-2020 and is not only related to the pandemic and the war in
Ukraine, but also to issues already related to the increase in
production costs, to the debate on transition of the production model
[i.e. the EU’s ‘farm to fork’ initiative],” and to commodity
speculation. Leite added that the number of investment funds globally
that are backed by agriculture grew from fewer than 50 in 2005 to
more than 600 in 2020.
Despite this, an action plan to address food insecurity released by
the World Bank, IMF and other international financial institutions
(IFIs) in May failed to even mention financial speculation – and
rather focused on (inter alia) promoting open trade, mitigating
fertiliser shortages and supporting increased food production. The
lack of acknowledgement by the IFIs of the role of the
corporatisation of agriculture in the current crisis is concerning,
as the Bretton Woods Institutions have played an important role in
facilitating the financialisation of the sector over recent decades
(see Observer Spring 2020, Spring 2018).
The action plan’s launch followed a declaration signed by over 280
civil society organisations in October, ahead of the 2021 Finance in
Common Summit, which called “for an immediate end to the financing of
corporate agribusiness operations and speculative investments by
public development banks,” and renewed focus on supporting “peoples’
efforts to build food sovereignty, realize the human right to food,
protect and restore ecosystems, and address the climate emergency.”
Crisis in a time of plenty: Bank and Fund back free trade solutions
As Frederic Mousseau of the US-based Oakland Institute noted in a 30
May op-ed for Inter Press Service, “There is no food shortage.
According to a May 6, 2022 report by the United Nations Food and
Agriculture Organization (FAO), the world enjoys ‘a relatively
comfortable supply level’ of cereals.”
Rather, the current crisis reflects power asymmetries in the global
food system. Clapp argues that, “the production of the world’s staple
crops destined for export is concentrated in a small number of
countries, and they are shipped around the world by a handful of
trading firms…Add to this concentrated global food system the
financial markets, which can further exaggerate the effects of price
shocks.” In fact, despite increasing global food outputs, the number
of undernourished people, according to the World Health Organisation,
has been steadily growing since 2015 after years of decline, reaching
811 million in 2020.
Rather than calling out financialised interests, however, both the
World Bank and IMF have instead vocally opposed countries introducing
trade restrictions. For example, the World Bank’s April 2022
Commodity Markets Outlook argued that, “Recently…policy responses
have tended to favor trade restrictions, price controls, and
subsidies, which are likely to exacerbate shortages.”
The IFIs’ action plan released in May likewise noted that, “The IMF
is engaging its members and is working with the World Bank, the WTO,
and others to promote open trade. The IMF’s trade policy tracker is
monitoring trade restrictions on food and agricultural inputs and
has…identified…20 countries that have resorted to such practices
since the start of 2022.”
Mousseau noted the example of India, where both the US and IMF have
sought to convince the country to lift a suspension of wheat exports.
He argued, “Their cited concern is that export restrictions will
exacerbate food shortages… But the argument does not stand ground
technically or morally.” Moussueu added: “The US produces roughly 400
million tons of corn, but over 40 percent of this amount – 160
million tons – goes to ethanol production, while another 40 percent
goes to animal feed, and only 10 percent is used as food whereas
another 10 percent is exported. India was not expected to export more
than 10 million tons of wheat in 2022-2023.”
Bretton Woods Institutions’ policies have actively contributed to the
current food systems status quo
As Flora Sorkin noted in an April 2020 At Issue briefing, “The World
Bank and IMF have played a pivotal role in facilitating the
financialisation trend [in agriculture] through their support for
market-led land reforms and financial sector deregulations, which
enabled private investors’ access to large-scale land deals in
developing countries and further speculation over commodity futures”
(see also Inside the Institutions, The World Bank and agriculture).
The Bank’s Enabling the Business of Agriculture rankings, which were
discontinued as part of the wider Doing Business Report scandal in
2021 (see Observer Autumn 2021), included a land indicator aimed at
promoting large-scale land acquisitions by foreign investors,
according to 2019 research by the Oakland Institute. A 2020 report
also by the Oakland Institute included six case studies where the
World Bank was a key player in the large-scale dispossession of rural
lands. This included in Ukraine, where, “the World Bank and the
International Monetary Fund leveraged the economic fallout from the
COVID-19 pandemic to coerce ‘Europe’s basket’ into putting its
agricultural land for sale in a land market” (see Observer Winter
2019).
Meanwhile, the World Bank is currently urging countries to resist
introducing universal food subsidies in an apparent continuation of
earlier, ill-fated Bank interventions during the period of
‘structural adjustment’, when food and agriculture subsidies were
slashed under World Bank reforms (see Update 62). The World Bank’s
director for development finance, Samuel Maibo, told the East African
website in May that, “The World Bank position is that subsidies are
effective if temporary or targeted. If you do not have these two
working carefully, the risk of mismanaging subsidies is high.”

IFC’s response risks further consolidating power of commodity traders
There is arguably a direct link between such policies and the
continued concentration of power by a handful of global agricultural
commodity traders. Clapp noted that just four companies, Archer-
Daniels Midland, Bunge, Cargill and Dreyfus, control “the bulk of the
world’s commercial grain trade…These global corporations hold large
reserves of grain, but do not publicly report them, nor is there a
requirement for them to do so. This lack of transparency makes it
impossible to get a clear view of global stores of grain, which
contributes to further volatility.”
As noted in Oxfam’s May 2022 Profiting from Pain report, recent years
have seen an unprecedented boom for agriculture traders’ profits. In
2021, Cargill had a “net income of $5bn and made the biggest profit
in its history….The company is expected to make record profits again
in 2022.”
As part of its efforts to bolster production, the International
Finance Corporation (IFC), the Bank’s private investment arm, is
considering finance for these same players, including a recently
approved $200 million loan to Dreyfus’s Brazilian subsidiary, which
drew opposition from civil society over human rights and
environmental concerns – as well as claims that the agricultural
production supported will mainly be used for animal feed (see
Observer Summer 2022). Such support appears part of IFC’s wider
strategy, with the IFIs’ action plan noting IFC will “focus on
facilitating financing to maintain trade flows of commodities from
alternative origins and meeting increased working capital needs of
its private sector clients along the supply chain…through financial
intermediaries as well as by directly lending to agribusiness
companies.”
Mousseau noted: “As hundreds of millions struggle to buy food, it is
difficult to say what is the most shocking: The record profits made
by a handful of multinational corporations that dominate the global
food trade or the ‘keep trade open’ mantra repeated tirelessly by
international financial institutions to sustain the business of these
corporations and speculators gluttoning on world hunger.”
bit.ly/FoodCrisisBWIs

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In this issue

- Why the IFC can’t afford to squander this opportunity to get remedy
right by Robi
Chacha Mosenda and Megan Pearson
- A new Bretton Woods for whom? Civil society calls for
democratisation of global governance
- The IMF is changing and needs an independent ombudsman
by Danny Bradlow
- Resilience and Sustainability Trust: Will “qualifying reforms”
bring long-overdue institutional shift?

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ACCOUNTABILITY/analysis

Why the IFC can’t afford to squander this opportunity to get remedy
right
By Robi Chacha Mosenda and Megan Pearson, Accountability Counsel

SUMMARY
- Responding to long-standing criticisms, the IFC is developing a
remedy framework
- The need for remedy mechanism is urgent given the legacy of harms
resulting from IFC projects
- Civil society stresses need for rights-based framework that
addresses projects with verified non-compliance

Communities affected by development projects and their advocates have
long known that development finance institutions (DFIs) do not
adequately remedy harms caused by their projects (see Observer Winter
2021, Autumn 2020, Summer 2020). In response to a directive from its
board in 2020, the International Finance Corporation (IFC), the World
Bank’s private sector arm, announced in April that it is developing a
remedy framework and that it will seek public consultation on the
plan later this year. It is critical that the IFC designs a rights-
based remedial framework and that other DFIs quickly follow suit.
The responsibility of DFIs to provide an effective remedy for harmful
projects is a human rights obligation essential to their “do no harm”
development mandate. However, for communities seeking justice for
abuse financed by the IFC, the World Bank, and other DFIs, remedy has
been long overdue. For example, in 2013, tea workers in Assam, India,
raised issues to the IFC’s Compliance Advisor Ombudsman (CAO), its
independent accountability mechanism, alleging dangerous living and
working conditions at tea plantations co-owned by the IFC (see
Observer Winter 2017). A 2016 compliance investigation verified that
the IFC had violated its Performance Standards on Environmental and
Social Sustainability, but to this day, the IFC has neither addressed
harms done, nor facilitated remedy for the affected workers and their
families.
Meanwhile, communities in Kampala, Uganda, facing evictions to make
way for a drainage channel supported by a $175 million loan from the
World Bank are calling for a more immediate response to abuses they
are suffering. They have sought redress through the World Bank
Accountability Mechanism’s new Dispute Resolution Service (DRS) (see
Observer Autumn 2021). This is the first case before the DRS, and it
is a critical opportunity for the World Bank Group to ensure
meaningful and sustainable remedy for the affected communities, who
were not consulted adequately about the dispossession of their homes
and land.
IFC’s opportunity to set the bar on remedy
So far, the IFC, which heralds itself as a leader in corporate
governance, is the only DFI that has committed to creating a remedy
framework. How will we know if the IFC gets remedy right? The basic
requirements of a rights-based remedy framework are already known. A
February 2022 UN report on Remedy in Development Finance recommended
that: (1) DFIs and their clients should both enable and contribute to
remedy for ethical and legal reasons, and because remedy is essential
to their development mandates; (2) opportunities to provide remedy be
built into each stage of every project; (3) DFIs establish financing
mechanisms for remedy; and (4) DFIs’ accountability mechanisms be
well resourced, and their mandates specifically include facilitating
remedy.
The most important reflection of whether the IFC gets remedy right
will be how it addresses the existing projects with verified non-
compliance, like Assam and the multiple other projects that the CAO
found to be non-compliant with the IFC’s Performance Standards and
dispute resolution processes that resulted in agreements. A truly
rights-based remedial framework cannot only be forward-looking but
must also commit to remedying the confirmed harms that communities
are experiencing now.
The UN report exposed as “questionable” some of the arguments that
DFIs have mounted for why they do not enable or provide remedy for
harm, including concerns about moral hazard and exposure to legal
liability. The worry that committing to remedy will disincentivise
borrowers from following the DFI’s performance standards fails to
critically consider that adherence to these standards is already
disincentivised: when project implementation falls short, the costs
are already externalised away from borrowers to local communities.
And arguments about legal liability often fail to consider the
formidable costs and procedural hurdles facing communities who seek
to bring legal actions against DFIs. Furthermore, adequately
responding to accountability mechanism findings and recommendations
in the first place may prevent legal liability down the road.
Given DFIs’ emphasis on a risk-based approach, it is shocking that
they fail to plan for the inevitable: That harms occur despite
preventative efforts. By neglecting to set aside funds for remedy at
the outset of every project, DFIs open themselves to the substantial
risk that their operations will leave communities worse off than
before. Now that the IFC is in a position to finally get remedy
right, it can pave the way for other DFIs and usher in a new standard
for development effectiveness. But if the IFC’s new framework falls
short of a rights-based commitment to remedy project harms, and if
other DFIs, including the World Bank, don’t quickly commit to
establishing remedy frameworks, then local communities will continue
to pay the price and continue to lack remedy for violations of their
human rights.
bit.ly/IFCRemedy

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SOCIAL SERVICES/news

World Bank’s commitment to private sector-led development casts doubt
on effectiveness of new Pandemic Preparedness Fund

SUMMARY
- Bank slated to be trustee of new fund, despite concerns about its
private sector bias
- Civil society calls for fund’s board toinclude representatives of
all stakeholders, including from the Global South

The World Bank’s support for business interests, including through
the World Bank Group president’s stated opposition to the TRIPS
waiver during the pandemic (see Observer Summer 2021) raises serious
questions about its proposal for a Financial Intermediary Fund (FIF)
for Pandemic Prevention, Preparedness and Response. The FIF,
announced in the G20’s Spring Meetings press briefing (see Dispatch
Springs 2022), will leverage a range of private and public resources
to support international initiatives, with the Bank providing
financial intermediary services as trustee.
Civil society organisations (CSOs) have been strongly critical of the
initiative. “Development actors should prioritise public over private
provision, especially for primary healthcare, as recently noted by
the Lancet commission on Primary Healthcare,” said Marco Angelo, of
Belgium-based Civil Society Organisation Wemos. He added, “Private
provision negatively affects equitable access when it is not
integrated in the public health financing system; when integrated, on
the other hand, it can present many challenges.”
Belgium-based CSO Eurodad also argued private healthcare should not
be prioritised over public provision, echoing calls from experts at
the 2021 World Bank and IMF Annual Meetings (see Dispatch Annuals
2021).
The proposed FIF raises several concerns, not least relating to the
Bank’s preferred support for the private sector at the expense of
public provision. This was evident even in response to the Covid-19
pandemic, which clearly demonstrated the importance of integrated
public health systems capable of providing universal access to
quality healthcare.
The proposed TRIPS waiver and vaccine inequality
During the pandemic, World Bank President David Malpass opposed
temporarily waiving intellectual property rights (The Agreement on
Trade-Related Aspects of Intellectual Property Rights, better known
as TRIPS) for Covid-19 vaccines, which would have allowed any country
with the capacity to produce Covid-19 vaccines, potentially vastly
expanding the global supply and allowing developing countries access
to many more doses of vaccines at cheaper prices (see Observer Summer
2021).
Without the TRIPS waiver, which was supported by the vast majority of
the Bank’s own shareholders, low-income countries were forced to
depend largely on an ill-suited international support system in which
charity and solidarity played a disproportionate role, including
through the World Bank-supported COVAX facility. As a direct result,
as of March 2022 developed countries have fully vaccinated 79 per
cent of their populations, while only 14 per cent of people in
developing countries have been vaccinated. The recent deal on
Covid-19 vaccine patents agreed at the World Trade Organization
announced in June fell far short of a full intellectual property
waiver and may even make it harder for countries to access vaccines
in a future pandemic. Vaccine inequality is a large part of the
reason why the death toll in developing countries was four times
higher than in developed countries.
The Bank’s support for pharmaceutical companies did not stop at
Malpass’s opposition to the TRIPS waiver. Last year, the Bank paid
over $600 million to pharmaceutical giants Pfizer and Moderna
for their Covid-19 vaccines, via contracts awarded through COVAX –
$352.8 million to Moderna and $284.6 million to Pfizer. Pfizer
doubled its overall profits last year on the back of its vaccine
sales, while Moderna, selling only its vaccine, made $13 billion pre-
tax profits on nearly $18 billion revenue.
Questions over FIF governance and representation
The proposed FIF also raises concerns about governance and
representation. The suggested governance structure of this FIF would
likely see the board primarily composed of large donors – namely
wealthy countries from the Global North. Global South countries would
likely be restricted to observers with little voice in key decision-
making processes, even though they disproportionately bore the brunt
of the Covid-19 pandemic and are likely to do so with any future
pandemic. The proposed structure mirrors the Bank’s own governance
deficits and contravenes calls for democratisation of the
multilateral system in general and of the BWIs in particular (see
Observer Summer 2022)
Oxfam’s response to the Bank’s White Paper on the FIF called for the
governing board to include key representatives of all stakeholders
with equal weight for recipient and donor governments, and for the
FIF to be hosted by the World Health Organisation, a recognised
expert in the field of global health, and not the Bank.
bit.ly/WBGFIF

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WORLD BANK-IMF ROLES/analysis

A new Bretton Woods for whom? Civil society calls for democratisation
of global governance

SUMMARY
- Growing geopolitical tensions amidst worsening economic outlook
threaten current multilateral order
- Calls for a new Bretton Woods to support status quo and failed
economic policies have become mainstream
- Civil society demands democratisation of world economic order

As the unequal recovery from the Covid-19 pandemic and the war in
Ukraine exacerbate pre-existing economic, climate, social and
political challenges (see Dispatch Springs 2022), the multilateral
order is once again in the mainstream spotlight. Calls now abound for
a new Bretton Woods moment, recalling the establishment of the United
Nations and the World Bank and IMF in the aftermath of World War II.
Calls for New Bretton Woods overlook the system’s imperialist origins
On 18 April, the Financial Times published an article supporting US
Secretary of State Janet Yellen’s proposal for a new Bretton Woods
arrangement in a 13 April statement. Secretary Yellen noted the need
for a multilateral system in which countries are not able to “use
their market position in key raw materials, technologies, or products
to…exercise unwanted geopolitical leverage.” US-based think tank
Atlantic Council has recently launched a Bretton Woods 2.0 Project.
Discussions about the need for a new international order have once
again clearly moved beyond the confines of its ‘usual critics’ (see
Bretton Woods at 75 conference; Observer Summer 2019).
Secretary Yellen’s remarks about the need for a new Bretton Woods
moment to respond to imbalances in global power and “unwanted
geopolitical leverage” is rather strange when one considers the
origins of the Bretton Woods system and the interests it was designed
to protect. As professor Celine Tan from the University of Warwick
notes, “the governance and operational structures of the Bretton
Woods Institutions continue to represent contemporary geopolitical
and economic realities rooted in colonialism and imperialism.”
Given the obvious disparity in the nature of the critics, the
pressing issue is therefore what vision of a reformed international
order will prevail: One that perpetuates or deepens the interests of
international and national elites and financial capital with roots in
empire, or one that democratises global governance, redistributes
power among states in the Global South and North, is able to respond
to the climate crisis, enables all citizens to avail themselves of
their human rights, and reverses the increasing financialisation of
the global economy and related commodification of essential public
services?
Calls for a new international order are not new. In February 2014, at
the 70th anniversary of the Bretton Woods Institutions (BWIs, i.e.
the World Bank and IMF), and in the aftermath of the 2008 global
financial crisis, then IMF Managing Director Christine Lagarde
delivered a speech in which she highlighted the need for a “new
multilateralism for the 21st century.” In it she called for a more
inclusive multilateralism, based on the “values of a global civil
market economy” and stressed that the system must support “a
financial system that serves the productive economy rather than its
own purposes.”
As substantially documented, the former IMF Managing Director’s
assertions about the benefits of the system have been widely and
robustly contested (see Observer Winter 2020, Autumn 2019; Briefing
Bretton Woods at 75) both by the people who have suffered and
continue to suffer from its consequences, but also by volumes of
academic work. Despite Secretary Yellen’s pleas for a new ‘values
based’ multilateral system that legitimises the status quo, the
importance of addressing its persistent critiques has only become
more pressing in the aftermath of the Covid-19 pandemic and the food
security (see Observer Summer 2022) and energy crises exacerbated by
the war in Ukraine.
In response to multiple crises, advocates call for system reform, not
a new Bretton Woods
Aside from persistent calls by civil society for the BWIs to accept
their accountability under international human rights law and recent
documentation from the UN Conference on Trade and Development
(UNCTAD) that commodity dependence remains a trap and has increased
since 2009, it is worth also noting that the putative poverty
reduction claimed by advocates of the current system is disputed (see
Observer Winter 2017-2018). That is, the current system has failed to
deliver on its promises to reduce poverty and to bring about the
economic transformation that would enable citizens to avail
themselves of their human rights and live within ecological
boundaries.
Any effort to develop a new Bretton Woods must thefore address the
BWIs’ inherently undemocratic governance structures by ending the
gentleman’s agreement (see Background, What is the gentleman’s
agreement), radically adjusting their voting and board structures and
enhancing the ability of countries in the Global South to influence
their policies and programmes. A new Bretton Woods would also address
the IMF and World Bank’s equivocal interpretation of their position
within the UN system, where they refuse to accept their
responsibility under international human rights law, and require them
to develop a human rights framework and related policies.
A Financing for Development conference could provide an opportunity
for progress in these areas. As underscored by Farwa Sial from
Belgium-based civil society organisation Eurodad, “Current rethinking
of the Bretton Woods Institutions is driven by its most powerful
members serving their own interests. A Financing for Development
summit at the UN would be a much more equal and effective setting,
giving every country the chance to negotiate the blueprint for new
rules and institutions governing global finance, the economy and
trade. This would be an opportunity to break out of this power
deadlock.”
Within this context, the efforts of global social movements and
allies such as Philippines-based Ibon International and the Asian
People’s Movement on Debt and Development, and women’s rights
organisations such as India-based Development Alternatives with Women
for a New Era to reframe the discussion and call for a people-
centred, just and ecologically sustainable world economic order,
remain essential.
As Jason Braganza from the African Forum and Network on Debt and
Development noted, “a rules-based system cannot ignore the voice of
developing country regions like Africa anymore. The pandemic,
climate, conflict, and other systemic challenges are all evidence of
Africa’s deepening role in the global politics, economics, and more
broadly. Thus any reforms need to have African leaders at the table
as rule makers not rule takers.” Indeed, Professor Tan stressed that
“a reformed international economic architecture would account for the
impact that industrialised countries and their powerful financial
actors have played in creating global collective problems from
climate change to sovereign debt and financial crises to trade wars
and military conflict. The responsibility for addressing these crises
must rest on these powerful actors and they must account for their
actions and make appropriate reparations” (see Observer Autumn 2020).
FfD4: A rare opportunity for concrete structural change?
While exchanges at the Eurodad 2022 conference in Brussels in June
ranged from vaccine inequality to “Ensuring the primacy of human
rights in times of systemic crises”, discussions also took place
concerning the importance of supporting calls for the likely forth UN
Finance for Development Conference (FfD4) during 2023 to seek
urgently needed structural reforms to the international architecture.
While recognising that the UN system is not immune from the power
imbalances on which the current global economic order is anchored,
participants noted that a 4th conference could provide an important
mechanism for structural changes, such as a UN tax body, a UN debt
workout mechanism or a global financial transaction tax. They
highlighted that the UN’s governance structure – which, unlike the
BWIs – allows every state an equal voice and has a unique ability to
take legally binding decisions that affect the international
financial architecture, makes FfD4 an important forum for collective
action.
Participants in the discussion also recognised that, given the
interests aligned against significant structural changes, as
articulated in the ‘Billions to Trillions’ agenda (see Observer
Autumn 2017), the World Bank’s Green, Resilient, Inclusive
Development framework and increased reliance on ESG investments as a
developmental tool, a truly concerted effort by social movements,
civil society, labour unions and progressive academics will be
required to counter efforts to use the ‘new Bretton Woods moment’ to
deepen the current failed model and to take concrete steps toward a
more just economic system.
bit.ly/NewBWMoment

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PRIVATE SECTOR/news

World Bank’s IFC ends funding for fee-paying primary and secondary
schools

The International Finance Corporation (IFC), the World Bank’s private
sector arm, announced on 8 June that it would not resume its
investments in for-profit fee-paying private primary and secondary
schools, following a critical report by the World Bank’s Independent
Evaluation Group (IEG) published in January.
This means the IFC’s temporary suspension of all direct and indirect
investments in for-profit schools announced in 2020 is now permanent
(see Observer Summer 2020). The suspension followed a campaign
mounted by civil society organisations (CSOs), in particular in
Africa, and a March announcement that the IFC was divesting from for-
profit education provider New Global Schools, previously known as
Bridge International Academies (BIA; see Observer Spring 2022).
The IFC noted in a June 8 statement responding to the IEG evaluation
that “there is potential” for investment in private schools to
exacerbate inequality and have unintended consequences for the public
sector school system.
The move was widely welcomed by CSOs, which have long criticised
IFC’s funding of for-profit education (see Observer Spring 2018). In
a CSO statement, Magdalena Sepúlveda of the Global Initiative for
Economic, Social and Cultural Rights called for the World Bank Group
to provide “increased support to governments to build stronger and
more equitable public education systems, through its public sector
support.”
The negative impacts of private capital investing in for-profit
education providers, such as BIA, are now widely recognised. The
right to inclusive and equitable quality education is enshrined in
Sustainable Development Goal 4 (SDG), and last year, UNESCO’s Global
Education Monitoring (GEM) Report 2021/2 stated that “profit making
is inconsistent with the commitment to guarantee free pre-primary,
primary and secondary education.”
bit.ly/IFCPrivateSchools

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TRADE/background

What is the World Bank’s International Center for the Settlement of
Investment Disputes (ICSID)?

A new Bretton Woods Project Inside the Institutions piece looks at
the World Bank’s International Center for the Settlement of
Investment Disputes (ICSID), which is the main forum for Investor-to-
State Dispute Settlements.
ICSID was established in 1966 by the Convention on the Settlement of
Investment Disputes between States and Nationals of other States.
Currently, ICSID includes 164 member states in contrast to the 193
member states of the UN.
The article details civil society concerns about ISDS, which allow
states to be sued by foreign corporations alleging violations of
international trade treaties – with such cases potentially
undermining the human rights of communities affected by foreign
investments, as well as frustrating climate action in cases where a
phaseout of foreign-owned fossil-fuel infrastructure is required to
meet national climate goals.
bit.ly/WBGICSID

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FINANCE/news

Highly indebted countries face further cuts to public spending to
service debts, as IMF austerity bites

SUMMARY
- Highly indebted countries forced to prioritise debt repayments
- Need for an effective mechanism of debt relief more urgent than
ever

A May report by UK-based civil society organisation Debt Justice
(DJ), formerly Jubilee Debt Campaign, found that public spending in
the most indebted countries is falling or stagnating, “despite the
need for countries to increase their spending in response to the food
and energy prices hikes” (see Observer Summer 2022).
Using IMF data from 41 low-income countries where information is
available, the report noted that “the countries with highest debt
payments of over 15% of government revenue faced a drop in public
spending of 3% between 2019 and 2023, compared to an increase of 14%
for the countries with the lowest debt payments.”
Currently, the only international mechanism for debt relief to which
countries have access is the G20 Common Framework for Debt Treatments
(see Observer Winter 2020). This has proven ineffective as none of
the three countries that have applied have had any debt cancelled and
the involvement of private lenders in this scheme is still unclear,
despite several calls from civil society organisations (CSOs) and
leadership at both the IMF and World Bank (see Observer Winter 2021).
Tess Woolfenden of Debt Justice highlighted that given the lack of an
effective debt relief scheme, “Lower-income countries are being
forced to prioritise debt payments over public spending on healthcare
or access to food, right at a time when spending is so urgently
needed… Debt repayments to wealthy lenders should not take precedence
over people’s needs in a time of multiple crises.”
Inequality crisis worsens in the absence of solutions to rising debt
Debt and human rights experts have raised concerns about continued
IMF-mandated austerity, warning that the inequality crisis will be
exacerbated by hikes in food and energy prices (see Observer Summer
2022) and the high level of external debt payments – which according
to DJ is now as its highest since 2001.
A 2021 paper by Isabel Ortiz and Matthew Cummins, which focused on
projections of future spending to 2025, warned of a “post-pandemic
fiscal austerity shock…far more premature and severe than the one
that followed the global financial crisis.” In a July 2021 blog, IMF
Managing Director Kristalina Georgieva noted the Fund’s concerns
about “a worsening two-track recovery, driven by dramatic differences
in vaccine availability, infection rates, and the ability to provide
policy support” and called for “urgent action by the G20 and
policymakers across the globe.”
However, the IMF’s own promotion of austerity measures in highly
indebted countries (see Observer Winter 2021), and other policies
such as IMF surcharges (see Inside the Institutions, What are IMF
Surcharges?; Observer Spring 2022), are forcing countries to
prioritise paying back their debts over meeting their international
human rights obligations.
In July, UN Secretary-General Antonio Guterres stressed the need for
immediate debt relief for low-income countries. He also noted that,
“efforts are also needed to create sovereign debt workout mechanisms
that can significantly reduce the disproportionate burden placed on
developing countries, while bringing all creditors to the table.”

Debt workout mechanism under UN auspices one key solution
Longstanding calls for a United Nations-based debt workout mechanism
that guarantees responsible lending where all actors, including the
private sector, take part in line with international human rights
norms remain pressing (see Observer Spring 2022). The possibility of
a 4th Financing for Development Conference (FfD4) could bring an
opportunity to establish such a framework at the UN. As highlighted
by the Civil Society Financing for Development Group, this mechanism
would be key to “address unsustainable and illegitimate debt
including through extensive debt cancellation” and move towards an
economic system that “works for people and the planet.”
Sri Lanka recently witnessed the collapse of its economy,
unilaterally suspending $25 billion of foreign debt payments. Mass
protests since March due to high levels of debt, the impact of the
Covid-19 pandemic and the rising costs of commodities led to the
president’s resignation in July. Without urgent action taken to
tackle the debt crisis, Sri Lanka is widely seen as a harbinger of
more defaults by other countries to come.
bit.ly/DebtCrisisReport

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ACCOUNTABILITY/commentary

The IMF is changing and needs an independent ombudsman
By Danny Bradlow, American University Washington College of Law

SUMMARY
- The IMF has substantially expanded the scope of its work to include
climate change, gender, the pandemic and inequality
- The broadening of its work increases the risks to communities and
individuals
- The IMF must establish an ombudsman to receive and investigate
complaints about the negative consequences of its programmes


The fact that the IMF has recognised that issues like pandemics,
climate change, gender discrimination and inequality influence macro-
economic stability is to be welcomed. So is the fact that the Fund
has begun to incorporate these issues into its research and its
regular consultations with its Member States, and is proposing to
include them in the scope of financing facilities such as the
Resilience and Sustainability Trust (see Observer Spring 2022).
However, it is concerning that the IMF has not yet fully recognised
how these issues challenge its usual way of doing business.
They require the IMF to interact directly and systematically with
non-state actors in its Member States so that it can understand how
these issues affect communities, organisations and individuals, and
how they may respond to particular IMF policy proposals. This
increases the risk that the IMF’s own activities may directly and
adversely affect these non-state actors. The principles of good
governance require that the IMF be accountable for these impacts.
This article argues that the IMF should appoint an ombudsman who can
receive and investigate complaints about the way in which it has
exercised its power. This will help the IMF address the operational
challenges posed by these new issues.
Three challenges facing the IMF
First, these issues blur the boundaries between the macro- and micro-
impacts of economic, social and environmental policies. For example,
a full understanding of the impacts of climate policies includes
assessing both their macro-level financial and fiscal implications,
and their differential impacts on sub-national governments,
businesses, communities, regions, and social groups. These impacts –
and the response of these groups to them – can both affect the
success of climate policies and have implications for inequality and
discrimination in the Member State. The IMF, therefore, can only
fully assess the likely success of the proposed policies if it
consults with all these groups about the policy.
Second, policies addressing these new issues operate over longer time
periods than the usual IMF operations. Thus, the IMF staff, in
developing them, must take more variables into account. They must
also directly consult with a broad range of state and non-state
actors, who will now have time to adjust their conduct to the
policies, thereby influencing their success or failure.
Third, the IMF staff and the Member State cannot address all of these
issues in any particular country mission or financing arrangement.
They will have to decide which ones to prioritise. The staff,
therefore, will need to decide whom to consult about these choices
and what information they should make available in these
consultations.
These new issues, therefore, necessarily require IMF officials to
take decisions that can have a substantial impact on the lives and
wellbeing of the residents of its Member States.
The IMF has only partially responded to these challenges. For
example, its current Guidance Notes envisage that staff can undertake
consultations but do not establish formal procedures that staff
should follow in deciding whom to consult or about which issues. They
also do not provide staff with clear guidance on the scope of the
impact assessments they should undertake (see Observer Summer 2021).
IMF needs mandatory staff guidance and an ombudsman
First, management should formulate a set of publicly available
mandatory policies that explain how staff should manage the
environmental and social aspects of macroeconomic policy. Staff
should make decisions based on reliable data, appropriate
consultations with all stakeholders and without fear or favour of any
particular stakeholder. The policies should clarify the IMF’s
approach to information disclosure. They should stipulate the
criteria for assessing the adequacy of consultations with all
relevant stakeholders and the environmental and social impacts of
current and proposed macroeconomic policy.
Second, the IMF board of executive directors should appoint an
ombudsman who is independent of IMF management, reports to the board
and can hold the IMF staff and management accountable for their
compliance with these policies.
This official should have the authority to receive and investigate
complaints from external stakeholders who claim they have been harmed
by the failure of IMF staff and management to comply with the IMF’s
own operational policies and procedures. After completing the
investigation, the ombudsman should submit to the Board a publicly-
available report documenting its findings and making recommendations
about how to address any harm caused by the IMF staff’s non-
compliance with the applicable policies and procedures. The ombudsman
should also issue an annual report that, when appropriate, discusses
the lessons it has learned about IMF operations from its
investigations.
Currently, the IMF is the only international financial institution
without an independent accountability mechanism. It is time it
corrects this deficiency and appoints an independent ombudsman.
bit.ly/IMFOmbudsman

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PRIVATE SECTOR/news

Report on privatisation of Kenya’s healthcare highlights human impact
of World Bank’s private sector bias

A November 2021 report by the Center for Human Rights and Global
Justice at New York University (NYU) titled Wrong Prescription: The
Impact of Privatising Healthcare in Kenya provides a damning picture
of the rapidly expanding role of private sector healthcare in Kenya
promoted by the World Bank under its Maximising Finance for
Development (MFD) approach (see, Observer Spring 2022, Summer 2017).
It finds that privatisation can compromise universal access to
healthcare (a human right under both the Kenyan Constitution and
international human rights law) by diverting resources away from the
public sector and prioritising services focused on profit. The trend
of financialisation, both generally and of essential public services
in particular, has been noted by civil society as a concern for
states fulfilling their human rights obligations (see Observer Spring
2022).
Despite well-founded concerns, Kenyan policymakers, urged on by
development actors such as the World Bank, have adopted policies to
increase private sector participation in the country’s health system
by subsidising private care, pursuing public-private partnerships
(PPPs; see Observer Autumn 2015) and offering tax incentives to
investors. The NYU report concludes that healthcare privatisation in
Kenya is bad value for taxpayers and has had severe negative human
rights impacts for Kenyans, proving costly for individuals and the
government while pushing Kenyans into poverty and crushing debt.
The report adds to civil society concerns about the promotion of
private solutions by international financial institutions (IFIs). The
report states that private actors are “insulated from the obligations
and democratic processes associated with the public sector”, and
international actors who influenced Kenya into privatising its
healthcare system are “arguably even less accountable” than private
actors. The World Bank and others failed to respond to questions from
the authors about whether they assess the impact of their support for
private sector healthcare on human rights, social risks, or access to
healthcare.
Joint author Rebecca Riddell commented: “The World Bank has
aggressively pushed for more private sector participation in
healthcare in Kenya, despite widespread concerns about rising costs,
inequality in access, and uneven quality of care. These are not just
minor problems that can be downplayed or blamed on regulators—they
really go to the core of whether the MFD approach is fit for
purpose.”
bit.ly/WBGKenya

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ENVIRONMENT/news

Resilience and Sustainability Trust: Will “qualifying reforms” bring
long-overdue institutional shift?

SUMMARY
- IMF and World Bank to define “qualifying reforms” to access finance
from new RST fund over the summer
- BWIs’ questionable track record on climate and fossil fuel finance
calls into question their expertise to determine countries’ climate
policies

After a year-long civil society campaign calling on rich countries to
re-channel their unused Special Drawing Rights (see Inside the
Institutions, What are Special Drawing Rights (SDR)?) to poor
countries struggling with Covid-19 pandemic response, climate shocks
and growing debt burdens, in April the IMF established the Resilience
and Sustainability Trust (RST; see Dispatch Springs 2022). As the IMF
ventures into lending for long-term balance of payment challenges for
the first time, the RST’s design remains flawed: Eligibility is tied
to countries having an existing IMF programme; disbursement is via
loan financing with a tiered interest structure, rather than grants;
and a quota-based access limit means countries with small quotas or
high levels of existing debt will hardly benefit (Observer Spring
2022). Moreover, the $45 billion funding aspiration seems
staggeringly unambitious compared to the minimum $6 trillion of
climate finance needs calculated by the UN Climate Change Conference
(UNFCCC), especially given that G7 countries currently have $1
trillion in SDRs on their balance sheets.
The RST will also require countries to undertake yet-to-be-defined
‘qualifying reforms’ related to climate change or pandemic
preparedness to access finance, with the IMF working with the World
Bank to design these reforms. The April RST board paper emphasised
that reforms would be identified by Fund and Bank staff, and national
authorities’ strategies considered only “where applicable”, casting
doubt on a truly country-led approach. Other sources of expertise
like the UNFCCC or civil society remain unmentioned. The accompanying
press release suggests “reforms supported by the Trust are also
intended to catalyse increased financing from the private sector,”
indicating an unwavering focus on a market-led transition.
Given the ubiquity of fiscal consolidation measures across almost all
recent IMF loan programmes (Dispatch Springs 2022), as well as the
contradictory approach of both institutions on climate and fossil
fuel investment (Observer Winter 2021, Autumn 2021), the implications
of the Fund and Bank assuming decision-making power over countries’
climate policies and related public spending needs are problematic.
Indeed, in an April report, Chiara Mariotti from Brussels-based civil
society organisation (CSO) Eurodad highlighted “serious risks that
the RST will lock countries into multiple frameworks of
conditionality and undermine their already limited policy space.”
IMF’s expertise to prescribe climate policies remains questionable
Recognising the “macro-criticality” of the transition risks of the
economic transformation away from fossil fuels, the IMF developed a
climate strategy in 2021 that included proposals for a serious
expansion of staff capacity (Observer Autumn 2021). However, research
by ActionAid USA and the Bretton Woods Project published in August
2021 demonstrated that the Fund advised over half its members to
continue investing in fossil fuels in the six years prior, including
expanding fossil infrastructure, privatising energy and utility
companies, and more. Mozambique is a case in point (see Observer
Summer 2022, Autumn 2020), where the
Fund predicted a coal and offshore gas boom and developed a regime of
tax breaks for investors, only for the main coal mine to become a
stranded asset, and the country’s flagship gas project to be halted
over increased insecurity and violence. Mozambique’s debt has
ballooned partly as a result, an outcome that a serious assessment of
transition risks might have accounted for.
While the IMF can – in theory – play a crucial role in navigating the
macroeconomic impacts of climate change and mitigation policies to
support a just green transition, including through the RST, this will
need a deep institutional shift beyond scaling-up climate staff and
collaboration with the World Bank. “The current approach is a
continuation of the type of policies that the IMF and World Bank have
imposed since the era of Structural Adjustment Programs, which have
for decades failed to deliver meaningful outcomes on development
goals,” said Lara Merling of Boston University’s Global Development
Policy Center. “It’s unclear how doubling down on the same approach
is now expected to result in a different outcome on achieving climate
goals, while also supporting countries’ development outcomes.”
bit.ly/RSTClimate

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GENDER/news

World Bank’s new gender strategy: Concerns about approach to social
protection and gender-blind macroeconomic reforms remain

SUMMARY
- Care and social protection may be potential focus of new World Bank
gender strategy
- Civil society cautions that Bank’s proposed support for privatised
childcare provision risks repeating past mistakes

With the World Bank’s current gender strategy set to expire next
year, hints of the focus of the new strategy are keenly anticipated.
While the Bank has confirmed that development of the strategy is yet
to begin, a focus on care and social protection has emerged in its
gender work. One challenge for the Bank will be to stop undermining
the targeted work of the gender team with fiscal consolidation and
regressive tax-focused loan conditions in its Development Policy
Financing. The Bank’s current gender strategy, for fiscal years (FY)
2016-23, focuses heavily on themes such as improving human
endowments, removing constraints for more and better jobs and
removing barriers to women’s ownership and control over assets. Civil
society have criticised the strategy’s instrumentalist approach to
women’s empowerment, the lack of a system of accountability, and the
absence of a macroeconomic lens (see Observer Winter 2016).
IDA20 replenishment provides insights into direction of travel of
Bank’s gender work
Possible insights into what may lie ahead can be gained from the 20th
replenishment of the International Development Association (IDA), the
Bank’s low-income country arm, in December 2021, where a range of
gender policy commitments were made. The Gender and Development
special theme contains a commitment to support “at least 15 IDA
countries to expand access to quality affordable childcare,
especially for low-income parents,” which has resulted in the
creation of a Childcare Incentive Fund.
A briefing note for the Childcare Incentive Fund makes clear that it
will seek to both expand public provision of childcare, as well as
support for ‘non-state’ actors, including ‘chains of private
providers’. However, recent negative outcomes of the Bank’s support
for for-profit education providers (see Observer Summer 2022) and
privatised healthcare (see Observer Summer 2022), raise serious
concerns that the fund will serve as a vehicle for further Bank-
promoted privatisation of vital social services. Fiana Arbab of Oxfam
International commented, “It is deeply concerning to see expectations
of the ‘nonstate sector to expand provision’ including for-profit
enterprises, and ‘chains of private providers’ in the Bank’s current
draft concept note on the Fund knowing there is significant evidence
from for-profit models in the K-12 education sector that demonstrate
when there are fees, no matter how low, certain income groups are
excluded. For-profit models should therefore be avoided altogether
due to the gender and economic inequality and quality of provision
impacts.”
Bank must ensure its macroeconomic policy does not undermine gender
equality
The Bank also risks overriding more targeted gender efforts if its
macroeconomic policies remain gender blind. The Bank continues to
support austerity policies through prior actions in its development
policy finance instrument (DPF; see Inside the Institutions, What is
World Bank Development Policy Financing?; Briefing, Learning lessons
from the Covid-19 pandemic: The World Bank’s macroeconomic policies
and women’s rights), which have a particularly negative impact on
women and girls, as the burden of stretched household income and
reduced public services is felt mostly by them. The continued
adherence to fiscal consolidation and touting of for-profit
“alternatives” in
the midst of severe crises contradicts the Bank’s commitment to the
Sustainable Development Goals and risks undermining its own gender
targets.
Elsewhere, civil society has critiqued the implementation of current
Bank social protection policies. In a June 2020 report, UK-based
consulting firm Development Pathways highlighted the contradiction
between the World Bank’s stated focus on ‘universal social
protection’ and evidence of its continued promotion of a targeted
approach to it. The Bank has a history of advocating for the
implementation of targeted, means-tested protection systems, which
can lead to significant targeting errors, often not reaching those
who need support the most (see Observer Spring 2018).
On the World Bank’s work going forward, Mareen Buschmann of Care
International UK noted, “Covid-19 has rolled back progress on gender
equality by a generation, and for instance increased the time that
women and girls spend on unpaid care and domestic work by a further
30-40 per cent… We’d encourage the Bank to go beyond childcare,
expand the country portfolio to 25-30 IDA countries accelerating
action, invest in creating decent care jobs, and integrate a gender
lens across recovery from crisis, be it from Covid, conflict or the
climate emergency.”
bit.ly/WBGCare

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FINANCE/news

Restart of Pakistan’s IMF loan agreement collapses with change in
government, as soaring costs of IFC-supported LNG add to fiscal pain
Pakistan has reopened negotiations with the IMF to resume a $1
billion disbursement of its stalled $6 billion Extended Financing
Facility, after prime minister Imran Khan was ousted in April
following a no-confidence vote, scuppering a deal to restart the loan
programme (see Observer Spring 2022).
The previous restart of Pakistan’s IMF loan had drawn the ire of
Pakistani environmental civil society groups, as a mini-budget linked
to the programme had removed tax breaks for imported renewable energy
components and electric vehicles, in a blow to the country’s agreed
national climate targets (see Observer Spring 2022).
According to a 3 June article in the Financial Times, Pakistan’s
government is now increasing the cost of energy to its citizens –
despite the global food and fuel crisis (see Observer Summer 2022) –
in an effort to meet the IMF’s conditions. The FT noted, “The
government…has raised fuel prices by more than a third in two
separate moves this month after requests by the IMF to remove
subsidies.”
Among the issues exacerbating Pakistan’s fiscal crisis is its growing
reliance on importing liquefied natural gas (LNG). A June report from
the US-based International Institute of Energy Economics and
Financial Analysis (IEEFA) found that, “Increasing reliance on LNG
has exacerbated energy insecurity and financial struggles for the
government, household and business, and economic sectors,” warning
that this has exposed the country to commodity price shocks.
The International Finance Corporation (IFC), the World Bank’s private
investment arm, played a pivotal role in investing in Pakistan’s
first LNG import terminal in 2015, providing $35 million in loan and
equity support to the project, according to research published in
April by Netherlands-based civil society organisation Recourse.
bit.ly/IMFPakistanLoan

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LAND/news

IFC approves loan to industrial agriculture producer in Brazil
despite pleas for protection of sensitive grassland biome
On 1 July, online environmental publication Mongabay reported the
approval of a $200 million loan by the International Finance
Corporation (IFC), the World Bank’s private sector lending arm, to
“industrial agricultural producer Louis Dreyfus Company (LDC) for
monoculture soy and corn production in Brazil’s Cerrado, a grassland
biome that has lost nearly 80% of its habitat cover.”
The decision was heavily criticised by local human rights and
environmental protection organisations. The loan was approved despite
a 31 May letter signed by over 200 Brazilian, Latin American and
international civil society organisations, including Amigos da Terra
– Brasil and Haki Nawiri Afrika, calling on the executive board to
reject the loan. The letter argued that LDC would use the proceeds
from the IFC loan to purchase commodities from the “heavily
threatened Cerrado biome of Brazil, the world’s most biodiverse
savanna that has already lost roughly half of its native vegetation
to agribusiness.”
The letter also highlighted the risk of human rights violations and
land conflicts, deforestation and environmental degradation in the
sensitive Cerrado, and noted that the corn and soy would be
principally used for animal feed in damaging industrial farming
operations. It is concerning that the IFC chose to support
agricultural production being used for animal feed. Given the
evolving food crisis, the orgins of which are rooted in the
financialisation of food systems and predate the war in Ukraine (see
Observer Summer 2022, Spring 2020), the use of the resources for
animal feed is nonetheless a concern in light of the current context.
Additionally, the letter noted that, “LDC lacks a full traceability
system and its zero deforestation policy does not fully apply until
the end of 2025.”
The letter cited research that alleges that LDC and its subsidiaries
have contributed to deforestation and land conflicts and stressed
that the loan is inconsistent with the World Bank’s climate
commitments (see Observer Summer 2021).
bit.ly/IFCBrazil

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