Cultivating Ethics and Values FY17 ANNUAL REPORT Ethics & Business Conduct CONTENTS Who We Are 1 Letter from the Vice President and Chief Ethics Officer 2 Outreach, Training, and Values 3 Ethics Advisory Services 6 Business Integrity Review 10 Looking Ahead 18 Contacting EBC 20 The Ethics and Business Conduct Vice Presidency (EBC) promotes the development and application of the highest ethical standards by staff members in the performance of their duties. Who We Are The World Bank Group’s twin goals are to eliminate extreme poverty by 2030 and to boost shared prosperity for the bottom 40 percent of each developing country. For the diverse workforce of the Bank Group, integrity, ethical behavior, and adherence to corporate values are core to the success of these goals. Every year, thousands of Bank Group staff interface with EBC for guidance in ethics, help navigating Staff Rules, advice on the ethical dimensions of operations, customized trainings—and also for concerns about potential misconduct. EBC is an independent vice presidency within the Bank Group that reports directly to the president. independence, impartiality, and integrity 1 LETTER FROM VP and Chief Ethics Officer Thank you in advance for taking the time to read In addition, this EBC’s Annual Report for fiscal year 2017. Our year EBC started performance, our successes are measures of the to explore a more culture and reputation of the World Bank Group, diverse repertoire so your attention to this is very welcome. of corrective mechanisms when asked to address issues that fall short of misconduct or are more I am extremely pleased to present this report, as appropriately resolved at a lower level—while it has been a pivotal, very busy year for EBC. continuing to conduct investigations when Key to this is our restructuring in response to necessary. This is an important point, which leads recommendations from the external review we me to the last achievement to highlight in this letter. began at the end of last fiscal year. Through this, The most important measure of EBC’s EBC created an Outreach, Training, and Values effectiveness is whether staff come to us unit to focus on cultivating a proactive approach with their concerns. We were pleased to see a to ethics—emphasizing values, education, and significant increase in the trust staff place in prevention. A strong communications plan the Bank Group’s internal justice system, as underpinned these efforts. This year the unit measured by the general staff survey for 2017. focused on soliciting input from across the Bank We share pride in this improvement with our Group to feed into our new corporate values that colleagues across the internal justice system. will launch this fall. I want to heartily thank Bank Group management We posted a senior EBC staff member to the for supporting EBC’s new direction. I also thank field for the first time to increase our access to our strong partners in the Internal Justice country offices. We also made more outreach Services, the Human Resources Development Vice and training visits to country offices this year. At Presidency, the Legal Vice Presidency, the Staff a personal level, it was a great pleasure to meet Association, and our informal Sounding Board. I many colleagues across the globe to learn about offer my gratitude to the many colleagues who how their needs and circumstances relate to have responded to our outreach with enthusiasm EBC’s work. and to those who have the confidence in our work The restructuring also allowed us to review our to come to us for advice and action. delivery model, strengthen protocols, and reduce My very deep appreciation also goes to EBC staff transaction costs. I assure you that EBC is who work behind the scenes with confidence, and stronger and nimbler because of these efforts. professionalism to support the mission of the However, there is much more to this year’s story. Bank Group and contribute to increasing respect The ethics office of the Bank Group is only fully and fairness in our workplace. performing its role when we create more bridges Sincerely, with operations; here we have begun to make significant inroads. EBC has the knowledge to help identify conflicts of interest, dilemmas, consequences, and gaps in projects that have ethical and risk implications. We look forward to Ousmane Diagana, more ways to leverage this expertise. Vice President and Chief Ethics Officer 2 Outreach, Training, and Values The Importance of a Values-based, Ethical Culture Inspired by how Ford CEO Alan Mulally used values and behaviors to drive a cultural renewal at Ford Motor Company, Bank Group President Jim Yong Kim recognized the need to revisit the dated values statement for the World Bank and apply it across the Bank Group. In March of 2016, Bank Group senior management endorsed the Refreshing our Values initiative, recommending a bottom-up approach that would articulate and celebrate Bank Group core values, provide cues for behavior and decision making, and help motivate staff to deliver at full capacity. EBC and the Human Resources Development Vice Presidency (HRDVP) have led the initiative and, in FY17, undertook extensive staff consultations—hearing from more than 400 staff from across the Bank Group in focus groups and more than 500 staff through an all-staff online engagement. The new Bank Group core values will be launched in fall 2017. After finishing the design and piloting phase, in FY17 EBC began rolling out a new workshop—Creating a Respectful and Harassment-free Workplace—in regions and Washington, DC. EBC staff delivered the workshop to staff in ten country offices and to one headquarters-based unit, with very positive feedback. EBC has grown the cadre of trainers prepared to deliver the workshop both from within the unit and among partners from the Internal Justice Services and HRDVP to increase the reach of the workshop. EBC also continued to provide Ethics Awareness training throughout the fiscal year. A 2013 National Business Ethics Survey showed unequivocally that misconduct declines as ethics culture MISCONDUCT DECLINES AS ETHICS CULTURE IMPROVES improves. The survey asked whether staff had witnessed Weak | 88% misconduct in the previous Weak-Leaning | 59% 12 months. In organizations Strong-Leaning | 32% with a weak ethics culture, 88 Strong | 20% percent of staff said they had. By contrast, 20 percent of staff Employees Who Observed Misconduct in Previous 12 Months reported seeing misconduct in organizations with a strong ethics culture. A 68-point © 2014, Ethics Research Center. Used with permission of the Ethics Research Center, www.ethics.org difference tells its own story. 3 In FY17, EBC reached 3,949 staff directly through outreach and training activities in Washington, DC and the following 30 country offices: Abidjan, Accra, Addis Ababa, Bangkok, Beirut, Bucharest, Cairo, Chennai, Chisinau, Colombo, Dhaka, Freetown, West Bank and Gaza, Hanoi, Kampala, Kathmandu, Kigali, Lomé, Luanda, Marrakesh, Mexico City, Monrovia, Nairobi, New Delhi, Port Moresby, Sana’a, Singapore, Sydney, Tbilisi, and Yaoundé. LOCATIONS OF OUTREACH AND TRAINING ACTIVITIES IN FY17 TRAINING BY TOPIC (staff attendance) 1,553 989 Ethics Awareness Creating Respectful 400 Ethics at Work 1,007 Refreshing our and Harassment-free Learning Series Values Workplace 4 Communications Strong communications underpinned EBC’s efforts to cultivate a values-based ethical culture this year. In FY17 EBC launched a well-read newsletter sent to all Bank Group staff, revamped our internal and external websites, touched colleagues with a high-visibility poster campaign (see graphic below), and continued our successful Ethics at Work series—holding three standing-room only events during the year. EBC also concentrated on regular, transparent communication of results through Bank-Group intranet kiosks, blogs from the Vice President and Chief Ethics Officer, and a town hall open to all staff that was livestreamed to country offices. We all have a part to play. What’s yours? ETHICS is not a spectator sport. Colleagues at the Ethics and Business Conduct Vice Presidency (EBC) can provide advice and support. Learn more at http://ethics.worldbank.org 5 Ethics Advisory Services In FY17, EBC focused on boosting awareness among Bank Group staff of its role as a resource for advice on adherence to values, compliance with rules, assessment and management of conflict of interest risks, and—increasingly—support to policy and strategy. As a result, FY17 was one of the busiest on record for Ethics Advisory Services. EBC responded to 846 requests for advice this year, compared to 777 requests in FY16. Despite the increase, EBC maintained its commitment to rapid response: 67 percent of queries were answered on the same day; 85 percent were answered within one day; 90 percent were answered within two days. On average, queries were answered within .8 of a day. Approximately half the queries concerned either outside activities or future/former employment relationships. EBC noted that—due to more widespread knowledge of our ability to address these issues—operational questions tended to be more complex than in the past. This led to active collaboration between Ethics Advisory Services and operational teams. Policy reforms that took place this fiscal year, such as the development of guidelines on operational conflicts of interest, also have allowed EBC to deepen collaboration, share knowledge, and make the rules friendlier to operations. 6 TABLE 1. CONFLICT OF INTEREST CONSULTATIONS BY CATEGORY   FY17 FY16 FY17 FY16 Outside activities 311 284 37% 37% Future or former employment 103 112 12% 14% Close relatives /relationships 112 112 13% 14% Vendor procurement 60 50 7% 6% External service 48 48 6% 6% Gifts, medals, honors 47 42 6% 5% Personal financial interests 17 20 2% 3% Public statements & disclosures 40 32 5% 4% Operational 20 29 2% 4% Other 88 48 10% 6%   846 777 100% 100% CHART 1. CHART 2. ETHICS ADVISORY SERVICES ETHICS ADVISORY SERVICES CONSULTATIONS BY SOURCE CONSULTATIONS BY GRADE LEVEL MIGA GEF Others GA to GD UA and UC Non-classified 14 7 18 71 79 18 2% 1% 2% 8% 9% 2% GH+ IFC 235 165 28% 20% IBRD 642 75% GE to GG 443 52% QUERIES RECEIVED IN FY17: 52 percent of queries 36 percent were from 9 percent of queries 3 percent came from came from regular term staff came from short-term others (for example, staff or staff under consultants retirees, future hires, open-ended contracts and relatives of staff members) 7 Declaration of Interests Program EBC oversees two Bank Group Declaration of Interest (DOI) programs, which are designed to mitigate real or perceived conflict of In 34 cases, EBC closed its review upon providing interest risks. guidance to staff—for example, alerting them The Senior Management Team and Vice to potential conflicts of interest that could arise Presidents DOI Program requires the 40 most in the event of changes to their work program senior individuals in the organization, including relevant to their financial holdings.  In the the Bank Group President, to complete a remaining cases, EBC implemented additional declaration that is summarized and publicly remedies, including directing staff to disclose posted on the internet. All new vice presidents particular assets to their manager (10 cases), receive individual briefings at the start of their requiring staff to recuse themselves from working appointment on compliance with the conflict on certain projects or deals (eight cases), and of interest requirements of the Bank Group and requiring staff to seek the approval of either their senior management regularly consult EBC for manager or the Outside Interests Committee guidance on conflicts of interest concerns. in order to continue an outside activity or employment (four cases).  This year, in no case The Staff DOI Program requires manager-level was a staff member required to obtain EBC staff members, as well as designated staff in approval prior to purchasing or selling an asset other sensitive roles, to complete a confidential or to divest. This reflects the generally high DOI that is reviewed by EBC and external awareness of management-level staff concerning consultants to identify possible conflict of the Bank Group requirements about financial interest risks. (Members of the Bank Group assets and outside positions. Board are also subject to financial disclosure in a program that is run independently by the In FY17, all 2,393 staff who were requested to file Corporate Secretariat.) a Declaration of Interest in March 2017 complied with this obligation.  Of 2,352 declarations received in the FY16 DOI staff program, 93 percent were closed after an In the last week of June 2017, EBC requested initial review.  The remainder were referred by 37 additional filers to complete a Declaration the external contractor in the first part of FY17 of Interest form. This supplementary program, to EBC for further research. In approximately rendered necessary by the discovery of a one-third of these cases, EBC determined that computer bug, was completed at the end of no further action was necessary.  In 56 cases, July 2017. EBC contacted the staff member to request more information and closed the declaration review with no further action needed.  8 Outside Interests Committee The Staff Rules address staff members’ ability to participate in outside employment. While some activities do not require approval, others do. For certain staff grade levels, requests to engage in certain activities are considered by the Outside Interests Committee (OIC). The OIC comprises representatives from throughout the Bank Group and considers staff members’ requests to provide services to a for-profit entity or initiative, paid services to a non-profit entity, unpaid services to a non-profit entity that has a business relationship with the Bank Group, or services to a government. In FY17, the OIC considered five requests and all were approved. They included a general approval for U.S. citizen and permanent resident staff members to work at voting stations during the U.S. presidential elections in November and an approval to allow new staff to complete professional assignments with no relation to the Bank Group activities. The OIC also approved the principle that staff can generally accept an honorary doctorate subject to a review by EBC to ensure that no conflict of interest arises; only cases involving conflicts of interest would be referred to the OIC for review.   9 Business Integrity Review Regrettably, every organization faces staff who fail to uphold high standards of behavior. As part of our mandate, EBC diagnoses and manages incidents when staff bring forward concerns about potential misconduct, including workplace-related grievances, travel and benefits fraud, and staff noncompliance with personal legal obligations. This year 36 percent of cases were resolved, advised, or referred to other resolution mechanisms. This underlines EBC’s resolve to increasingly address allegations of inappropriate behavior that may not amount to misconduct through consultation, advice, and performance management—empowering managers and staff to make decisions within an ethical framework that translates into accountability and ownership. When this approach is not possible or appropriate, EBC investigates possible misconduct with commitment to the principles of proper due process and concern for victims. EBC’s investigative process entails the receipt of an allegation, an assessment to determine whether it falls within EBC’s mandate, a preliminary inquiry to determine if there is sufficient basis for undertaking an investigation, the investigation (if appropriate), and case documentation and closure. This year, 21 cases resulted in a formal investigation. If EBC finds sufficient evidence to substantiate allegations, and other resolution mechanisms are not available within the remit of EBC’s mandate, we submit a report to the Vice President of Human Resources Development, who imposes disciplinary sanctions if he determines misconduct has occurred. 10 66 percent of reporters 6 percent were 28 percent were non-Bank Group were regular staff consultants staff or anonymous reporters 52 percent of reporters were 30 percent were from 18 percent were non-Bank Group from Part 1 countries Part 2 countries staff or anonymous reporters 15 percent of investigation 67 percent of subjects were 16 percent of subjects’ grades subjects were grade level grade level GE and above were unknown (for example, GD and below subject was non-Bank Group staff, identity was unknown by the reporter, or staff member was seeking advice) 46 percent of reporters 32 percent were men were women (22 percent unknown) 28 percent of cases were from 57 percent were from Country Offices Washington, DC (15 percent were anonymous sources or external to the Bank Group) 11 TABLE 2: CASELOAD FY15-FY17 BY CATEGORY FY15 297 FY16 230 FY17 228 Non-Compliance with Non-Compliance with Non-Compliance with Staff Rules 64 Staff Rules 72 Staff Rules 60 Harassment 88 Harassment 51 Harassment 61 Abuse of Authority 48 Abuse of Authority 26 Abuse of Authority 31 Misuse of Bank Misuse of Bank Misuse of Bank Resources 36 Resources 19 Resources 21 Personal Legal Personal Legal Personal Legal Obligations 14 Obligations 18 Obligations 18 G-5 Domestic Issues 15 G-5 Domestic Issues 15 G-5 Domestic Issues 8 Retaliation 15 Retaliation 11 Retaliation 11 Sexual Harassment 7 Sexual Harassment 10 Sexual Harassment 11 Discrimination 10 Discrimination 8 Discrimination 7 Investigative processing time has been decreasing since FY15. The increase in investigative staff coupled with improved internal procedures and revised performance metrics has resulted in a shortening of EBC’s average time for investigations by 50 days in FY17. Similarly, the average time for a preliminary inquiry—that is, when EBC determines whether there is sufficient basis to undertake an investigation—has decreased by 29 days in FY17. TABLE 3: FY17 CASES SUBMITTED BY EBC TO HRDVP Location Category of Misconduct HRDVP Decision Subject’s Grade Level HQ G-5 domestic issues Comply with HR Operations and GF provide evidence of full compliance CO Hostile work environment Pending GD (harassment) CO Misuse of Bank Group resources Termination, bar to rehire, restriction GB of access to Bank Group buildings CO Misuse of Bank Group resources Written censure in file for 1 year, GC withholding of future pay increases for 2-year period 12 Location Category of Misconduct HRDVP Decision Subject’s Grade Level CO Misuse of Bank Group resources Termination, bar to rehire, restriction GA of access to Bank Group buildings, written censure in file indefinitely CO Misuse of Bank Group resources Termination, bar to rehire, full GB (benefits) restitution to WBG medical provider, written censure in file indefinitely HQ Misuse of Bank Group resources Pending GE CO Non-compliance with Staff Rules Written censure in file for 3 years, no GA (conflict of interest) pay increases for 3 years CO Non-compliance with Staff Rules Termination, bar to rehire for 5 years, consultant (reckless performance of duties) restriction of access WBG buildings for 5 years, letter of misconduct to remain on file for 5 years CO Non-compliance with Staff Rules Termination and bar to rehire consultant (reckless performance of duties) CO Non-compliance with Staff Rules Demotion to level GD and ineligibility GE (reckless performance of duties) for promotion for 3 years CO Reckless performance of duties Pending GH CO Non-compliance with Staff Rules Demotion to level GC and ineligibility GD (intentional misrepresentation of for promotion for 3 years facts to be relied upon) CO Non-compliance with Staff Rules Termination, bar to rehire, restriction GA (theft) of access to Bank Group buildings, written censure in file indefinitely HQ Hostile work environment No finding of misconduct by HR GH (sexual harassment) HQ Hostile work environment No finding of misconduct by HR GH (sexual harassment) HQ Hostile work environment Written censure in file for 3 years GG (sexual harassment) CO Non-compliance with Staff Rules Decision pending GC (theft) 13 Business Integrity Review CONTINUED Eighteen cases were referred to the Vice President of Human Resources Development in FY17 for a disciplinary determination based on EBC’s fact-finding.1  Below are synopses of some of the closed cases:  on-Compliance with Staff Rules (theft): A staff member stole a personal laptop computer >N belonging to another staff member from Bank Group premises. His employment was terminated with permanent bar to rehire. He was also barred from Bank Group premises and a written censure was placed indefinitely in his personnel file.  isuse of Bank Group resources (medical insurance fraud): A staff member submitted fraudulent >M invoices to the Bank Group medical insurance provider and received reimbursement. He was terminated, barred from rehire, required to return the amount to the Bank Group medical provider, and a written censure was placed indefinitely in his personnel file.  buse of Authority/Abuse of Bank Group funds relating to petty cash or property: A staff member >A coerced certain country office staff into colluding in the misrepresentation of repairs to Bank Group vehicles, falsifying petty cash requests for vehicle supplies, and working with auto repair garages to inflate the costs of vehicle repairs and supplies. The staff member was terminated, permanently barred from future employment with the Bank Group, and barred from Bank Group premises. Another staff member who was involved in this matter was also found to have committed misconduct resulting in a written censure in her personnel file and no salary increase for two years. 1 A total of 18 cases were submitted to the Vice President of Development Human Resources during FY17, which included 11 cases that were initiated in the prior fiscal year. Another staff member entered into a Memorandum of Understanding. 14 15 CASE STUDY How We Learn from Investigations: Preventing Fraud We all can easily agree that preventing fraud is EBC’s cross-unit collaboration led to a financial important. At EBC, we feel this even more acutely audit review of the monthly bank reconciliations given that we have this responsibility within a of selected country offices. Manual entries in SAP development institution, where we have a special were compared with balances in bank statements responsibility to protect funds that are destined to ensure they were fully reconciled. The review to eliminate extreme poverty and boost shared focused on country offices where it was identified prosperity. that only one accountant handled both cash and accounting systems. This year, EBC dealt with fraud cases whose lessons are applicable across the Bank Group. One In one office, the review uncovered bank charge case involved the management of unused travel entries in SAP during the previous 12 months, advances and repeated, fraudulent SAP entries in amounting to nearly $10,000, that were not a country office. There, we saw that inadequate reflected in bank statements nor receipts. This segregation of duties increased the risk of fraud. was a red flag pointing to the possibility of false We recognized this as a very important finding, as accounting entries and misappropriation of in resource-constrained environments colleagues unused travel advances. are often asked to multi-task. EBC shared these EBC’s ensuing investigation found that, as in the lessons with our partners in Bank Group oversight previously investigated case, one staff member in units, and—as a result—at least one similar case that office was responsible for handling both cash of fraud was discovered. 16 While of course it is unfortunate to find misconduct, EBC is taking a holistic approach to look for systemic issues and communicate them to relevant parts of the Bank Group. and accounting processes in SAP. In both cases, This year, EBC also investigated a case that found the line supervisor was located in another country a staff member misused Bank Group Resources and the supervisor’s visits to the country office by creating fictitious group travel requests for were scheduled ahead of time, which allowed for seminars and workshops, diverting travel advance the fabrication or manipulation of information. SAP invoices through accounts payable, receiving When we approached several staff members who advances through a private bank account, and had received cash advances, they all confirmed creating fictitious statements of expenses that they had returned any unused funds from without supporting documents. In this way, their travel advances—but none had requested or the staff member was able to misappropriate been offered a receipt for handing over the cash. $234,000. While his contract ended in the course of the investigation, HRDVP sanctioned the staff The lessons from these two cases are quite member with a bar from re-hire and restrictions in simple: EBC recommends that country managers access to Bank Group premises. avoid the use of cash wherever possible and maintain adequate oversight over all accounting Here too, EBC was able to identify control failures functions. It is also critical to ensure a separation in SAP that we shared with relevant units. of duties between staff members handling cash While of course it is unfortunate to find and those entering transactions in SAP. Country misconduct, EBC is taking a holistic approach office accountants should retain all requisite bank to look for systemic issues and communicate transaction records. Finally, where the use of them to relevant parts of the Bank Group. This is cash cannot be avoided, all staff members should important in order to resolve matters at the most use receipts to record cash transfers. If these appropriate level, while still safeguarding the measures are adopted, we hope to fend-off any Bank Group’s ethical norms. further potential copycat instances across the Bank Group. 17 Looking Ahead EBC’s year has been active, as we consolidated our reforms and completed our restructuring. EBC vision for the future is even more dynamic, as we endeavor to further strengthen the values-based ethical culture of Bank Group staff, delve deeper into operations where we can identify ethical concerns and conflicts of interest, and bring external awareness to emerging and sticky ethical issues in global development. Specifically, EBC will look to develop more partnerships like the one we forged in FY17 with the Global Environmental Facility (GEF), where we engaged with staff and supported the Secretariat to create an Ethics Committee of the GEF Council. Taking this further, we hope that EBC is recognized as a resource to help Bank Group clients set up effective and modern ethics frameworks and offices. In terms of our treatment of misconduct allegations, we will move from monitoring and reviewing cases to actively managing them with an eye toward even more effective resolution of conflict and increasing support to victims. Annual reports tend to give data within context—an acceptable first-level analysis. Nevertheless, in the coming year we will pay more attention to underlying trends and red flags. Are there misconduct categories that appear underreported or under-adjudicated compared to other organizations? What are the regional discrepancies in requests for ethics advice and reporting of alleged misconduct? Do fewer reports from a unit or country office represent a positive indicator or rather indicate an ethical 18 EBC vision for the future is even more dynamic, as we endeavor to further strengthen the values-based ethical culture of Bank Group staff, delve deeper into operations where we can identify ethical concerns and conflicts of interest, and bring external awareness to emerging and sticky ethical issues in global development. “black box”? Do withdrawn complaints signal fear of retaliation? Moving forward, we will conduct root cause analysis on several issues and continue to look toward more systemic approaches. Certainly, we’re looking forward to launching our new core values across the Bank Group in FY18. The challenge that we willingly embrace will be to keep the momentum going year-on-year. The Bank Group is inherently a values-based organization and they must be cultivated with care—and vigor. Indeed, the world—and the Bank Group—is changing rapidly and EBC expects to keep up. We recognize that to be effective, staff need to focus on their clients and partners, not on grappling with bureaucracy or inefficient processes.  EBC’s new approach is in line with agile methodology and the Bank Group’s strategic direction as outlined in the Forward Look. Our review of protocols, simplification of Staff Rules, and collaboration across units to achieve better results is a continuous mandate that will last through FY18 and beyond. At a broader level, the strategic frameworks that currently guide the Bank Group’s direction—including maximizing financing for development by leveraging the private sector and optimizing the use of scarce public resources—imply tremendous culture change for their success. Much of this culture change involves a high level of ethical decision-making: for example, do we continue this project to maintain the status quo, or re-think and re-direct it, for the greater development good? EBC is prepared to support the Bank Group fully in this sea-change. 19 Contacting EBC Staff are encouraged to report alleged staff misconduct either to their managers or to EBC. Managers have an obligation to report such allegations to EBC. EBC affords due process to all individuals involved in an integrity review—including those reporting alleged misconduct, witnesses, and subject staff members. Information about an integrity review and the identity of staff involved are disclosed only to individuals who have a legitimate need to know, consistent with Staff Rules. Staff have the option of reporting misconduct anonymously. However, no finding of misconduct can be made based on anonymous allegations unless the allegation of misconduct is independently corroborated. Retaliation or threat of retaliation by a staff member against any person who reports suspected misconduct, or who cooperates or provides information in connection with an integrity review, is prohibited. Retaliation or threat of retaliation constitutes misconduct in and of itself and may be investigated as such by EBC. Staff with questions relating to potential conflicts of interest are encouraged to contact EBC early, so that any concerns can be promptly addressed and effectively managed. Conflict of interest advice will be kept confidential between the advisory team and the staff member, but may be shared with others who have a legitimate need to know. For example, information that has been shared with EBC’s ethics advisory staff may be shared with EBC investigators if there is reason to believe that misconduct may have occurred. TEL: 202-473-0279 FAX: 202-522-3093 EMAIL: ethics_helpline@worldbank.org ETHICS HELPLINE: 1-800-261-7497 (24 hours, 7 days a week; multiple languages) INTRANET: http://ethics.worldbank.org INTERNET: http://www. worldbank.org/ethics 20 independence, impartiality, and integrity