A/HRC/45/28 standards for all staff within the institutions. 70 Furthermore, international financial institutions have reportedly established guidelines to support their staff to work in accordance with good practices in the areas of disclosure, public financial management, contract monitoring and procurement.71 Another significant aspect of prevention is the anticorruption due diligence undertaken by international financial institutions in relation to the projects in which they are involved. However, it is reported that the types of efforts that international financial institutions pursue in the field of anti-corruption diligence vary considerably, which is of concern to the Independent Expert.72 60. All international financial institutions have adopted whistle-blower protection provisions to address instances of reprisals linked to the denouncing of corruption in projects funded by these institutions. These provisions deal primarily with the protection of internal whistle-blowers, reportedly with varying degrees of success. While the Independent Expert welcomes these provisions, he calls upon international financial institutions to extend protection to external whistle-blowers when it is not yet in place, and allow whistle-blowers to appeal the outcome of investigations through a legal protocol.73 Furthermore, it is crucial that national authorities be systematically informed of and pressed to act on allegations of reprisals against external whistle-blowers. 61. In this connection, it is essential that anti-corruption activists be able to work in a safe environment that is conducive to the exercise of fundamental rights and freedoms, free from acts of intimidation, attacks and retaliation. As a result, as stressed in section A, international financial institutions must equally be vocal and reactive in protecting civil society actors who are targeted because of their anti-corruption work. They should similarly press the national authorities to investigate allegations of reprisals against civil society actors reporting on allegations of corruption. 62. More generally, the Independent Expert stresses the significant role that civil society can and should play in the fight against anti-corruption, including in the design, implementation, monitoring and evaluation of anti-corruption measures, through a sustained, participatory and inclusive stakeholder engagement with access to information. 74 Civil society has voiced concern that IMF does not have a coherent policy for engaging civil society in country reviews and that different member countries take different approaches. 75 At a meeting with an IMF delegation in 2019 in Washington, D.C., the Independent Expert was told that this concern was known to IMF and that there was good will on its side and room for improvement. The Independent Expert is hopeful that IMF will address this valid concern. (b) Investigations and sanctions 63. International financial institutions have set up independent bodies to investigate allegations of corruption and apply administrative sanctions to entities found guilty. AfDB has the Integrity and Anti-Corruption Department, ADB the Office of Anti-Corruption and Integrity, EBRD the Office of the Chief Compliance Officer, IDB the Office of Institutional Integrity, and the World Bank Group the Integrity Vice-Presidency. These bodies, which report directly to the heads of the respective institutions, can impose sanctions under the form of debarment from operations financed by international financial institutions and 70 71 72 73 74 75 16 Matthew Jenkins, “U4 Expert Answer: multilateral development banks’ integrity management systems”, U4 Anti-Corruption Resource Centre, 14 September 2016, pp. 8–9. Available at www.u4.no/publications/multilateral-development-banks-integrity-management-systems-2.pdf. Ibid., p. 8. “Special report forum”, Financier Worldwide. See Transparency International EU, Investing in Integrity? Transparency and Accountability of the European Investment Bank (Brussels, 2016). Marie Chêne, “U4 Expert Answer: mainstreaming anti-corruption within donor agencies”, U4 AntiCorruption Resource Centre, 27 January 2010, p. 9. Available at www.u4.no/publications/mainstreaming-anti-corruption-within-donor-agencies.pdf. M. Emilia Berazategui, “The IMF post-Lagarde: how to keep up anti-corruption momentum”, Transparency International, 11 September 2019.