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.

Reporting to the President and informing the Board of the World Bank Group

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 informs the Board of the outcome of a compliance appraisal and the outcome of a compliance investigation, after clearance from the President. CAO remains available at all times to provide briefings to the Board at its request.

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.


Independence and impartiality

CAO's independence and impartiality are of primary importance to foster the trust and confidence of local communities, project sponsors, nongovernmental organizations (NGOs), and other stakeholders involved in a complaint. This trust and confidence are prerequisites for CAO to help resolve project-related concerns..

CAO is not identified with or beholden to any sector or interest.  CAO's independence and impartiality are reinforced in a number of structural ways:

  • CAO reports directly to the President of the World Bank Group and is not part of the
    line management structure of either IFC or MIGA.
  • CAO staff are recruited by the CAO Vice President.
  • Staff are independent of the management structure of IFC and MIGA.
  • The Office of the CAO is physically located in a secure area, and only CAO staff have
    direct access.
  • The CAO Vice President and her/his staff exercise caution in becoming involved in
    internal processes within IFC and MIGA to maintain neutrality. This caution is balanced with the requirements of CAO's advisory role.
  • CAO professional staff contracts restrict staff members from obtaining employment with IFC or MIGA for two years after they end their engagement with CAO.

If an employee of CAO has a conflict of interest in relation to a particular complaint, that person will withdraw from involvement in responding to the complaint.


Confidentiality and information disclosure

Information disclosure and confidentiality are both important to the CAO. Although confidentiality
is essential in some ombudsman cases, disclosure of information is critical to the
CAO’s independence and impartiality, and in achieving solutions in some cases.

CAO’s Terms of Reference limit the ability of the CAO to disclose information publicly
on its own initiative. The CAO is bound by IFC and MIGA disclosure policies that require the
confidentiality of certain business information to be respected during communications with
parties. CAO is also bound by the Staff Rules of the World Bank Group, which require
staff to treat information with discretion and not to disclose information improperly. CAO
will also respect complainant requests for confidentiality, including confidentiality of their

Within the parameters of those constraints, CAO makes every effort to ensure maximum
disclosure of reports, findings, and results of CAO processes. CAO may communicate
directly with complainants and affected parties. CAO reports that present the CAO‘s conclusions
on an investigation may be released to the public, but CAO may not publish information
received in the course of an investigation if the disclosure of that material is restricted under
IFC or MIGA disclosure policies. CAO will indicate publicly when it has restricted disclosure
in response to a request from an affected party.


External 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