Boots on the Ground: Decentralizing Multilateral Investigations

Nodir Zakirov, Senior Investigator, Integrity Vice Presidency World Bank Group, 14 November 2022

For many years, investigative functions of most international organizations and multilateral development banks have been based in their respective headquarters. Although headquarters based centralized operation has its benefits, it also has some limitations. This was especially evident during the pandemic, when travel restrictions prevented investigators from conducting in-person interviews, document collection, and site visits, all of which affected the duration and closure of investigations. 

In the past several years, some of the international organizations and multilateral development banks started decentralizing their staff and resources to be closer to operations and their beneficiaries. Accordingly, their investigative offices are also moving away from having investigative staff just in the headquarters to employing investigative teams around the world.

I asked heads of the multilateral investigation offices for UNICEF, the Global Fund, and the World Bank Group whether they have investigative teams in the field, what the advantages and challenges of having local staff were, and how it facilitated their work. While each individual recognized common challenges on the issues involved, they had different outlooks on the topic that reflected the unique circumstances of their missions, mandates, and current resources for the organizations they served.

It’s a good example and reminder that for multilateral organizations, the factors behind any organizational decision for their investigative offices can be varied and complex, even for matters that might appear very similar at first glance.  

UNICEF

 UNICEF works in more than 190 countries and territories to provide humanitarian and developmental aid to children. Most of UNICEF’s more than 16,000 staff and resources are in the field, and less than 15 percent work at UNICEF headquarters in New York.

 Stephen Zimmermann, Director of UNICEF’s Office of Internal Audit and Investigations (OIAI), said that his office began planning a field presence before the pandemic and was driven by a desire to have staff in a wider range of time zones and able to deploy to operational locations more quickly. Currently, about 20 percent of OIAI’s investigative staff is based in Budapest, Hungary. Steve added that OIAI plans to double its presence outside of UNICEF headquarters offices over the next 18-24 months. This additional presence may be in a third geographic location near areas where the demand for investigations is high.

 In addition to being able to deploy more quickly, efficiently, and with a smaller carbon footprint, having local investigative staff can also reduce OIAI’s costs, Steve explained. UN salary and benefits are directly tied to duty station location, and most are lower cost than in New York. According to Steve, having investigation teams in the field also allows OIAI staff to interact formally and informally with other UNICEF staff as well as partners and donors.

 Having investigation teams in different time zones presents its own challenges, Steve explained. Because of time differences, remote management can be challenging, especially when it comes to training, staff meetings, and team building. Therefore, OIAI is continuing to evaluate the balance of field-based staff versus those in the headquarters as travel restarts, but at the same time, OIAI continues to expand its new initiatives to work and access data remotely.

 As climate change is expected to aggravate poverty, conflicts, migration, and food insecurity globally, I asked Steve to share his vision for the future of multilateral investigations. Steve indicated that growth in operations and increased needs for assurance will likely mean demand for investigations will continue to outstrip available resources. He believes that the challenge will be how best to prioritize investigative resources to maximize value to the organization and meet increasing requests for more granular oversight by donors. According to Steve, this will necessitate more sophisticated risk management to ensure integrity resources are addressing the most significant risks to the achievement of UNICEF’s goals of helping children around the world.

The Global Fund

The Global Fund is a worldwide movement to defeat HIV, tuberculosis, and malaria. It brings together all stakeholders – governments, donors, communities, private sector, and others – to help countries to tailor their response to the three diseases. To reduce costs and maximize funds for its beneficiaries, the Global Fund does not maintain country offices and relies on its country partners to implement grants locally. Over 1,000 Global Fund staff manage, monitor, and oversee grant funds based in Geneva, Switzerland.

 This model equally applies to the Global Fund’s Office of the Inspector General (OIG), said Tracy Staines, the Global Fund’s Inspector General. She explained that the OIG relies on investigative staff to travel to implementing countries, but where country context is key or specialist skills are required, the OIG employs consultants to help bridge any gaps. Tracy added that the OIG also allows proven and capable implementers and Global Fund assurance providers to investigate their own matters, which are carefully overseen by OIG staff. Similarly, the OIG also collaborates with local anti-corruption agencies where relevant. According to Tracy, these arrangements help the OIG keep its overhead costs at a minimum and allow the OIG to deploy its specialist resources on the critical or most impactful investigations.

 For the above reasons, the OIG has not ever seriously considered creating teams in other parts of the world. Tracy said that she could only see that changing if the Global Fund– an organization that prides itself on being agile, lean, and putting country-owned solutions at the heart of implementation – devolved outside of Geneva.

 Sharing her vision about the challenges posed by climate change and the future of multilateral investigations, Tracy stated that many international organizations, including their ethics and integrity functions, also have a responsibility to set parameters on sensible environmental measures – including business travel. Often times, they are just like the rest of the world: they view climate change risks as remote and are very slow to take action regarding current ways of working. Tracy suggested that a good starting point would be for organizations to set a clear example in terms of climate-responsible behaviors, and that even defining and categorizing the poor or woeful practices that lead to climate damage could help galvanize partners and implementers to act. In extreme circumstances, activities that significantly damage the environment could even be viewed as prohibited practices. She recognizes, however, that because the Global Fund does not have country offices and manage programs itself, the institution’s ability to influence those practices would be more challenging, particularly in countries where the quantum of the Global Fund investment is relatively small.

In terms of operational changes, Tracy added that the pandemic has doubtlessly demonstrated investigators’ ability to do more from home offices, rather than travel overseas. This includes remote data gathering and analysis, use of technological innovations and remote interviews as well as more obvious activities such as attending conferences and training. Tracy said that it should mean that ethics and integrity functions should think more creatively about how to perform their functions remotely, rather than go straight back to the pre-pandemic ways.

The World Bank Group

With 189 member countries, staff from more than 170 countries, and offices in over 130 locations, the World Bank Group is the largest international financial institution working on sustainable solutions to reduce poverty and build shared prosperity.

 This year, the World Bank Group’s Integrity Vice Presidency (INT) launched a pilot for the use of investigative staff based outside of the World Bank Group’s headquarters in Washington, DC. According to Mouhamadou Diagne, the World Bank Group’s Vice President of Integrity, this direction reflects both operational and strategic considerations.

 At the operational level, the pandemic exposed the significant ramifications of travel restrictions on INT investigations. Building flexibility into INT’s operating model can help enhance business continuity, particularly by deploying staff around key geographies where the World Bank Group’s work is generally concentrated. Mouhamadou said that for the initial two-year pilot, INT’s inaugural field staff will be based in the Bank’s West and Central Africa region, which has an important concentration of countries supported by the World Bank Group's IDA fund, as well as countries facing issues of fragility, conflict, and violence (FCV), an important priority for the institution’s development focus. Mouhamadou said that INT would evaluate the effectiveness of this piloted approach and, depending on its success and lessons learned from the experience, make further determinations on decentralization, potential additional locations, positions, or staffing shifts over longer term.

From a strategic perspective, Mouhamadou explained that having field-based staff may increase INT’s ability to be more proactive in timely identification and response to integrity risks. He believes that field-based staff can be more attuned to realities on the ground, develop a deeper understanding of local contexts and actors, and can gather information more quickly. Mouhamadou added that field-based staff could more readily engage and build relationships with local authorities, law enforcement agencies, and other anticorruption actors around the world. In Mouhamadou’s view, corruption is a much more international and multijurisdictional challenge today, so having these local partners that INT knows and can call upon, and vice versa, will help make INT’s work more effective and impactful.

As INT’s experience is limited in managing field-based staff, Mouhamadou recognizes that there may be some managerial challenges with the core team based in Washington, DC, and the need for the field-based staff to report to the headquarters-based manager. INT is also considering how to best integrate these new staff into the wider INT team, in an equitable manner, so that they do not feel isolated or left out of opportunities available to other staff. Mouhamadou added that there could also be practical challenges such as time zone differences, but one of the advantages of working for a global institution like the World Bank Group is that one becomes well acquainted with those issues and develops strategies for operating around them. Mouhamadou said that it was too early for INT to objectively evaluate the cost/benefit trade-offs of maintaining field-based investigative teams. He said that there were intangible considerations that also factor into the value of field-based staff, which INT would evaluate at the appropriate time.

For Mouhamadou, corruption is akin to theft. He said that not only do corrupt actors steal invaluable resources, but they also diminish the development outcomes of projects, and thereby steal a better future for the people who should benefit from these investments. Yet, Mouhamadou recognizes that even for a large organization like the World Bank Group, resources are finite and not enough alone to meet all of the challenges of today’s complex and interconnected world. He believes, therefore, that international organizations and multilateral development banks must do all they can to get the most value from development investments. Mouhamadou concluded that INT, and indeed all ethics and integrity offices, should work to ensure that there is accountability over the development resources that the international development institutions deploy and that the funds are used only for their intended purposes.

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