About the CAO : Governance

Arne Hoel, The World Bank

CAO's independence and impartiality are of primary importance to foster the trust and confidence of stakeholders involved in a dispute. CAO is not identified with or beholden to any sector or interest, and reports directly to the President of the World Bank Group.

CAO's Governance

Reporting Line

CAO's mandate and procedures are articulated in the Terms of Reference (TOR) for the Vice President, Compliance Advisor Ombudsman and CAO Operational Guidelines. Under its reporting structure, the CAO Vice President reports to the President of the World Bank Group.  CAO's three functions-dispute resolution, compliance and advisory- and all CAO staff report to the CAO Vice President.


All CAO reports are circulated to the World Bank Group President. CAO also provides a quarterly report to the President. CAO communicates with the Boards of IFC and MIGA (the Board) on a regular basis, sharing all CAO case reports for information purposes.

Specifically, CAO informs the President and Board when a complaint has been found eligible for assessment. CAO reports the outcome of an assessment to the President and informs the Board.   CAO also informs the President and Board of the conclusion of a dispute resolution case through the circulation of a conclusion report.  CAO informs the President and Board of the outcome of a compliance appraisal.


In relation to compliance investigations, a new interim procedure was introduced in 2019 within the existing governance framework to strengthen the Board’s role in the accountability process. This procedure was introduced pending the outcome of the 2019-20 External Review. The President submits to the IFC/MIGA Board, all Compliance Investigation Reports and IFC or MIGA Management Responses for review, advice, and direction. The advice and direction received from the Board informs the President’s decision regarding the clearance of Compliance Investigation Reports and IFC/MIGA Management Responses.


Under the interim procedure, CAO's budget is also submitted by the President to the Board for review, advice, and direction.

CAO publishes an Annual Report at the end of each Fiscal Year which is provided to President and Board, and disclosed publicly.  More detailed summaries may be provided to the President at periodic briefings. The primary focus of these reports and briefings is to provide an overview of the activities of CAO and monitor implementation of findings and recommendations made.

CAO also provides an annual update of its activities to the World Bank Group Board Committee
of Development Effectiveness (CODE), and conducts periodic technical briefings to supplement this information.


Read more about CAO's independence and impartiality, and approach to confidentiality and information disclosure here.


Effectiveness Reviews


External Review 2019-20

In 2019, the Boards of IFC and MIGA initiated an External Review of IFC and MIGA's Environmental and Social Accountability, including CAO's Role and Effectiveness. The review will consider the respective roles of the Board, management and CAO, including the governance and effectiveness of CAO comprising CAO’s three functions (Dispute Resolution, Compliance, and Advisory), the role of IFC and MIGA and their clients in identifying, mitigating and responding to concerns regarding adverse environmental and social impacts of the business activities each finances or insures, and the oversight function of the Board. More information about the External Review process, including the team of experts convened to conduct the Review is available here.


Past Reviews

CAO has initiated three independent reviews of its effectiveness since the Office was established in 1999.  The reviews have focused on whether CAO is delivering on its mandate, identifying CAO's strengths, and areas for improvement.  The CAO reviews were conducted by independent experts and sought input from CAO's diverse stakeholders. CAO has used the reviews to improve the effectiveness of its work, specifically delivering on its mandate through its three main roles—the dispute resolution, compliance, and advisory functions.


A summary of the CAO external effectiveness reviews, as well as the full reports, are available in the links below:

Summary of CAO's Three External Effectiveness Reviews, 2012


Internal Review of CAO Terms of Reference, Operational Guidance and Operational Practices, October 2010


A Retrospective Analysis of CAO Interventions Trends, Outcomes and Effectiveness, May 2006


Beyond Compliance? An External Review Team Report on the Compliance Advisor Ombudsman Office of IFC and MIGA, July 2003


External Peer Reviews

Compliance Peer Review

Over the past two years, CAO has undertaken revisions to its Monitoring and Evaluation (M&E) system to make it more robust and to help CAO to improve its work. In 2016, CAO implemented the latest addition to its M&E system, an external peer review of CAO’s compliance reports. For this review, CAO selected Dr. Lalanath de Silva, at the time a member of the Asian Development Bank’s Compliance Review Panel and a Director at the World Resources Institute. Dr. de Silva was selected for this role given his extensive background in the areas of environmental policy and compliance review. Since completing the review Dr. de Silva has taken up a position as head of the Independent Redress Mechanism at the Green Climate Fund.

The review finds CAO’s reports to be robust with evidence being even handedly set out and analyzed prior to reaching conclusions. The review also finds there was solid justification for the decision to investigate in each of the cases that proceeded to the investigation stage of the compliance process. The review makes recommendations in relation to structuring of CAO compliance reports and improving their readability for members of the public. CAO expects to conduct regular peer reviews of this type as part of its M&E system.


The report summary, as prepared by Dr. de Silva, is available below:

CAO Monitoring and Evaluation: FY17 Compliance Peer Review