IMF Ethics Office Annual Report 2019: Continuing Success

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ETHICS OFFICEContinuingSuccessANNUAL REPORT 2019

CONTENTS34MISSIONSTATEMENTMESSAGEFROM THEETHICS ADVISOR6111618SECTION 12019 ACTIVITIESAND OPERATIONSSECTION 2TRAININGAND OUTREACHSECTION 3MAJORDEVELOPMENTSECTION 4GOINGFORWARD20THE FUND’SCORE VALUES1

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MISSION STATEMENTThe Ethics Office provides independent ethicsadvice to the Fund and its staff and promotesethical awareness through outreach and training.The office is headed by the Ethics Advisor whoreports directly to the Managing Director undera limited term appointment not to exceed six years.3

MESSAGE FROM THE ETHICS ADVISOR:Continuing SuccessMy arrival in October 2015 marked a new phase for the Ethics Office: to focus on advice, training and outreach topromote the Fund’s ethics standards—relinquishing an investigative mandate. The change enhanced the efficiency ofthe advisory function through greater specialization. Over the past four years, the Office has experienced a constantincrease in requests for advisory services as compared to previous reporting periods. I believe this upward trend canbe directly attributed to heightened awareness of the value of the Ethics Office’s robust training and outreach program.This positive trend reflects a continuation of the successful implementation of the Ethics Office’s mandate to focus onadvisory services in support of managers and employees.Taking stock of our accomplishments over the past year, the most significant was the introduction of the Fund’s revisedretaliation policy. The Ethics Office advocated for and worked with the other offices of the Dispute Resolution Systemto conduct a review of the Fund’s retaliation policy with a view towards strengthening the overall policy frameworkfor how retaliation concerns are addressed within the organization. The revised policy was introduced in February2019 following consultations with key stakeholders and an extensive benchmarking exercise against current policiesat comparable international organizations.Another major accomplishment would be launching the current Mandatory Ethics Training cycle in March 2019.During this cycle nearly 2,700 headquarters-based staff, contractual employees and managers have received training,including the Managing Director and all Deputy Managing Directors: representing a completion rate of more than80 percent. With the third cycle of Mandatory Ethics Training for all Fund employees at headquarters nearly complete,the Ethics Office will deliver similar training this year to our colleagues in the field. The Office also received a requestfrom the Offices of the Executive Board of the Fund to deliver ethics training to the Executive Directors, Alternates,Advisors and staff on issues relating to their Code of Conduct.The Ethics Office continued other outreach activities such as presenting at the First Day Briefing for new staff,attending senior departmental staff meetings and briefing Resident Representatives in preparation for theirassignments in the field. The Office was also privileged to chair the 11th Annual Meeting of the Ethics Networkof Multilateral Organizations. In addition, the Ethics Office continued its collaboration with the University ofCergy-Pontoise School of Law by hosting students from the law and business ethics program.4

Looking forward to 2020, the Ethics Office will launch thenext cycle of Preventing Workplace Harassment trainingprogram for all Fund employees.I want to thank the Managing Director and the seniormanagement team for their support for ethics at the Fundover the past year.The Ethics Office team looks forward to working with allof you in the coming year.Olivia N. GrahamEthics AdvisorInternational Monetary FundMs. Graham joined the Fund on October 26, 2015. She has along and distinguished career in ethics, with over 25 years ofexperience in international settings, including at the WorldBank and the United Nations World Food Program. Prior toher appointment with the Fund, she was Director ofEthics for the International Fund for AgriculturalDevelopment in Rome, Italy.5

SECTION 12019ACTIVITIES ANDOPERATIONSCategories of Advice . . . . . . . . . . . . . . . . . . . . . . . . . . . 7Caseload: Advice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Advisory Cases—2019 . . . . . . . . . . . . . . . . . . . . . . . . . . 9The following section provides 2019 data illustratingthe range of ethics issues on which the EthicsOffice was contacted directly for advice. All thematters brought to the attention of the Ethics Officewere responded to and resolved through advisoryconsultations or referrals to other appropriate officeswithin the Fund.The tables and charts in this section assist the EthicsOffice and Management in identifying issues that mayrequire targeted attention. The tables for Advice byCategory show a review of data from 2017, 2018 and2019 to demonstrate overall trends since the 2016change in the mandate of the Ethics Office. The EthicsOffice has fully implemented the mandate to focus onadvice, training and outreach to promote the Fund’sethics standards. A review of the information belowprovides helpful indicators of how programs designedto develop greater awareness of and adherence to theFund’s ethical standards are being used, as well asindicators of their effectiveness.6

CATEGORIES OF ADVICECONFLICTS OF INTERESTObligations as anInternational CivilServantFinancial Conflictsof InterestPersonal Conflictsof InterestGiftsEXTERNAL COMPLIANCEPoliticalActivitiesHousehold Obligations(e.g. G4/G5, taxes anddomestic relations disputes)Post-FundEmploymentExternal ActivitiesWORKPLACE FAIRNESSRESOURCES &INFORMATIONPublications andPublic r PreferentialTreatment/BiasMisuse of Resources andNon-Public Inforrmation7

CASELOAD: ADVICEThe Advice categories correspond to the twelve Key Ethics Issues of primary concern to the Fund. Detailed guidance onthese issues, as well as on other ethics issues, can be found on the Ethics Office website under “Key Ethics Issues.”The information provided on the Ethics Office website includes links to relevant provisions of the Fund’s Code ofConduct, GAOs, and Staff Handbook, as well as helpful intranet articles and other resources.KEY ETHICS ISSUES8Obligations as anInternational Civil s andPress StatementsGiftsFinancial Conflictsof InterestHarassmentMisuse of Resourcesand Non-Public InfoPersonal Conflictsof eholdObligations

ADVISORY CASES—2019In 2019, the Ethics Office responded to 507 requestsfor advice. The total number of cases during the yearincreased by 38 (eight percent) as compared to 2018.This may indicate staff are more aware of potential ethicsissues, in addition to their knowledge of the Ethics Officeas a resource based on outreach activities.There was an overall decrease in requests for adviceinvolving Workplace Fairness issues from 96 in 2018to 84 in 2019 (12.5 percent). During the reportingperiod, concerns relating to Discrimination significantlyincreased from one to five (80 percent); however, theother areas remained constant or decreased. Specifically,requests pertaining to Retaliation declined from threeto one (67 percent) and requests for advice involvingHarassment decreased by 21 percent to 52 [34 hostilework environment; 12 bullying; two mobbing; two sexualharassment; and two abuse of authority] from 66 in 2018.Requests involving Unfair Preferential Treatment/Biasremained the same: 26.Of note, the number of requests for advice about Harassmenttrended downward for the first time over the past severalyears [16 in 2015, 22 in 2016, 41 in 2017, 66 in 2018, and52 in 2019]. A major factor that may be contributing tothis positive trend are the resources the organization hasput forth to help employees to not only identify instancesof workplace conflict and harassment, but also trainingabout how to respond to and resolve these concerns.There was an increase in requests for advice aboutExternal Compliance as compared to 2018: from 12 to 17(42 percent). This increase can probably be attributed tothe introduction of the current cycle of Mandatory EthicsTraining, which highlights the importance of taking careto ensure full compliance with Household Obligationssuch as taxes, G5 Visa domestic employee issues, anddomestic relations disputes.In the area of Resources and Information, there was anoverall decrease in requests for advice from 29 in 2018to 24 (17 percent). However, on closer review, requestspertaining to the Misuse of Resources and Non-PublicInformation decreased from 18 to eight (55.5 percent) andadvice about Publications and Public Statements increasedto 16 as compared to 11 in 2018 (45 percent). The changesin these metrics can likely be directly attributed to thetraining and outreach activities undertaken by the EthicsOffice to specifically address these issues.Generally, Conflicts of Interest advice remains asubstantial part of the Ethics Office’s work and is crucialto safeguarding the Fund’s reputation for integrity. In 2019,there was a 15 percent increase (332 in 2018 as comparedto 382 in 2019) in requests for advice about Conflicts ofInterest. In this category, there was a significant increasein requests for advice on issues involving Obligations asan International Civil Servant from 21 to 46 (119 percent).The Ethics Office also saw a large increase in requestsfor advice about Gifts in 2019, there were 60 requests foradvice as compared to 40 in 2018 (50 percent). This may bea direct result of training and outreach activities. Requestsfor guidance on External Activities (which includedrequests for leave without pay) remained constant.In general, requests for advice and guidance in all otherareas remained essentially at the same levels as the twoprevious reporting periods.9

ADVICE BY CATEGORY201720182019Obligations as an International Civil Servant272146Financial Conflicts of Interest222023Personal Conflicts of Interest161921Gifts294064Political Activities646Post-Fund Employment91617External Activities196212205Publications and Public Statements181116Misuse of Resources and Non-Public ousehold Obligations141217Retaliation331Unfair Preferential Treatment/Bias72626410469507TOTALADVISORY MATTERS BY TOPIC GROUP3429572496141720182017Workplace Fairness10122019469 Total410 Total30584332External Compliance507 Total382Conflicts of InterestResources and Information

SECTION 2TRAININGANDOUTREACHTraining . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Outreach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13TRAININGMandatory Ethics Training. In 2011, managementauthorized Mandatory Ethics Training for all Fundemployees for the first time. The training wasimplemented Fund-wide beginning in 2012 and isrequired to be completed every three years. Thecurrent Mandatory Ethics Training cycle was launchedin March 2019 and nearly 2,700 headquarters-basedstaff, contractual employees and managers havereceived training, including the Managing Directorand all Deputy Managing Directors: representinga completion rate of 83 percent. The training willcontinue in order to achieve the maximum goal.11

Ethics training is an invaluable educational exercise to raise awareness not only of the Fund’s core values, ethicsrules and related policies, but also to raise awareness of resources available to assist staff facing a problem in theworkplace. The current training focuses on identifying and resolving different types of conflicts of interest, such asexternal activities, gifts, post-Fund employment; the appropriate use of social media, and the importance of copyrightcompliance. The training also focuses on discrimination and retaliation—providing frameworks to address specificaspects of workplace fairness facing Fund employees.Peers for a Respectful Workplace. In 2019, the EthicsOffice worked with the Mediator and other Fund officesto help continue to expand the Peers for a RespectfulWorkplace (PRW) Program across the Fund. TheProgram provides an informal, confidential, trustworthyand readily available source of early assistance forstaff with questions or concerns about stressful ordifficult workplace issues, or who want informationabout dispute resolution options available at the Fund.In November 2019, the Ethics Office participated intraining for new PRWs on ethics issues.Other Training. In partnership with the Headquarters Security Team, the Ethics Office presented two 90-minutetraining sessions addressing sexual harassment in the workplace as part of Women’s Security Awareness Training.The training provided an overview of the Fund’s harassment policy and, utilizing an interactive polling tool, revieweda series of scenarios that prompted a discussion about resolution options.12

OUTREACHUniversity of Cergy-Pontoise School of Law.In June 2019, the Ethics Office hosted 36 students fromthe law and business ethics program of the Universityof Cergy-Pontoise School of Law—a high profile programaimed at students graduating and trained to becomeEthics and Compliance Officers. Since the creation of theprogram in 2008, the Fund has hosted students duringtheir learning trip to Washington, D.C. This year, the visitincluded an in-depth ethics discussion, a presentation byMr. Raphael Anspach [Senior Communications Officer]about the history and work of the Fund, and a tour ofthe Managing Director’s office, with remarks by theManaging Director.13

Ethics Office Open House. The Ethics Office hostedits seventh annual “I Ethics” open house gathering in2019. This annual event allows interested staff to learnmore about the role of the Office, test their knowledgeof the Fund’s ethics rules, and challenge the Ethics Officestaff by asking their own questions.14

Ethics Network of Multilateral Organizations.The Fund chaired the 11th Annual Meeting of theEthics Network of Multilateral Organizations (ENMO),conducted at the European Patent Office in Munich,Germany in July 2019. Membership in ENMO isinstitutional and comprised of the most senior ethicsofficers or representatives with the main responsibilityfor ethics functions in the international financialinstitutions (Bretton Woods), the United Nationsfamily of organizations and other multilateral andintergovernmental organizations institutionally relatedto the UN.Other Outreach. During the year, the Ethics Office continued other outreach activities such as presenting at theFirst Day Briefing for new staff, attending senior departmental staff meetings and briefing Resident Representativesin preparation for their assignments in the field. In addition, the Office presented at the quarterly mandatory G4/G5Orientation sessions conducted in partnership with the World Bank Group.The Ethics Office will continue to be available fordepartment-specific training requests and other outreach activities.15

SECTION 3MAJORDEVELOPMENTRevised Retaliation Policy . . . . . . . . . . . . . . . . . . . . . . 16REVISED RETALIATION POLICYThe Ethics Office advocated for and worked with theother offices of the Dispute Resolution System to conducta review of the Fund’s retaliation policy with a viewtowards strengthening the overall policy frameworkfor how retaliation concerns are addressed withinthe organization.The revised policy was introduced in February 2019following consultations with key stakeholders and anextensive benchmarking exercise against current policiesat comparable international organizations.16

It accomplishes three main goals: Clarifies the scope and applicability of the policy; Introduces a clear definition of retaliation and theprotected activities to which it relates (e.g., raisingan ethics concern in good faith through any of theestablished reporting mechanisms); and, Introduces a framework that includes an expeditedreview process to address complaints of retaliation,including a new type of administrative leave withpay as an interim protective measure available inappropriate cases.17

SECTION 4GOINGFORWARDPreventing Workplace HarassmentTraining for all Employees, Part II . . . . . . . . . . . . . . . 18Mandatory Ethics Trainingfor Colleagues in the Field . . . . . . . . . . . . . . . . . . . . . . 19Ethics Training for Membersof the Executive Board . . . . . . . . . . . . . . . . . . . . . . . . . 19Priority activities for 2020will include the following:PREVENTING WORKPLACEHARASSMENT TRAININGFOR ALL EMPLOYEES, PART IIAn e-learning tool is being developed to provide the nextcycle of Preventing Workplace Harassment Training for allFund employees. First mandated by the Managing Directorin 2018, the training program will be launched throughthe Fund’s Learning Portal in early 2020. This module,similar to the first, is being developed in accordancewith the Fund’s harassment policy to provide training onissues related to the different forms of harassment, toincrease awareness of these issues, and to promote awork environment and a climate of trust and tolerance,free of all forms of harassment.18

MANDATORY ETHICS TRAININGFOR COLLEAGUES IN THE FIELDETHICS TRAINING FOR MEMBERSOF THE EXECUTIVE BOARDWith the third cycle of Mandatory Ethics Training for allFund employees at headquarters nearly complete, theEthics Office will deliver similar training to our colleaguesin the field. Overseas training is expected to be carriedout through a combination of in-person and electronictraining options.At the request of the Offices of the Executive Board,the Ethics Office will deliver ethics training to theExecutive Directors, Alternates, Advisors and staff.This training will focus on issues relating to theirCode of Conduct.19

INTEGRITYINCLUSIONWe do what is right for our members, our communities,the Fund, and each other. We make hard decisions andtough choices. We do not compromise our values.We value diversity. We build diverse professionalnetworks and teams fostering an engaging and inclusiveenvironment that values individual uniqueness. We treatpeople as we would like to be treated. We respect eachother and do not tolerate discrimination.RESPECTWe treat our colleagues, whether supervisors, peers,or subordinates, with courtesy and respect, withoutharassment, or physical or verbal abuse.IMPARTIALITYWe are objective, neutral, and impartial in providingadvice and in discharging our professional obligations.Our professional judgment is not influenced by partisanpolitics, outside authorities or personal bias. We areresponsible to our members and earn their trust andconfidence every day.EXCELLENCEWe strive for excellence in our work and in all ourinteractions with our member countries and allstakeholders of the Fund. We work together to thehighest professional standards for the common publicgood of our global membership.HONESTYWe tell the truth. We are straightforward in ouractions and honest in our relationships. When we saywe will do something, we follow through and honorour commitments.THE FUND’SCORE VALUES20

Information disclosed by staff to the Ethics Office will be handledconfidentially unless it involves possible past misconduct or raisesa potential threat of physical harm. In such cases, information maybe disclosed to other IMF officials on a need-to-know basis.If you have an ethics question, please contact the office at ext. 39665,visit our office in HQ2 4A-152 or send us an email at ethics@IMF.org.You may also seek advice or report concerns about potentialmisconduct to the Ethics Office anonymously via the Integrity Hotlineat 1-800-548-5384 or www.integrity-helpline.com/IMF.jsp.

annual report 2019 success ethics office annual report 2019. 1 the fund’s core values 20 18 section 4 going forward 16 section 3 major development 11 section 2 training and outreach section 1 2019 activities and operations 6 message from the eth

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