Dr. Jim Yong Kim
1818 H St NW
Washington, DC 20433
25 July 2012
Dear Dr Kim
RE: Independent Review of the Doing Business Indicators
We, the organizations undersigned, welcome your initiative to set up a panel to review the Doing Business indicators. We urge you to ensure that any panel created to review these controversial indicators is fully independent and includes representatives from civil society organisations.
As demonstrated during the 12 July board meeting on the Doing Business Report 2013, there are very strong and divergent views on the report and indicators. You should also be aware of the fundamental flaws in its design that have been highlighted not only by the undersigned organisations over the years, but also by the Bank’s Independent Evaluation Group (IEG) in its 2008 report. These flaws, pointed out by ourselves and the IEG, have not yet been fully addressed.
We welcome the measures being taken to replace the Employing Workers Index with a Worker Protection Index. However, a more comprehensive review of the entire process must be done.
We welcome your initiative last week to set up an independent review panel. We believe there are several elements necessary to make the review panel effective:
- The review panel must be truly independent of the IFC and the World Bank Group in order that its conclusions be trusted and legitimate. This means that there should be no members of the Panel who are currently staff members or consultants of the World Bank, the IFC or the IEG;
- The panel should include representatives from a diverse range of civil society organisations, including but not limited to trade union confederations; and should consult widely as part of its review process;
- A draft terms of reference for the panel should be published and open to public consultation and to input from stakeholders, including civil society;
- The terms of reference should ask the panel to examine both the substance of the Doing Business Indicators as well as the manner in which they are used;
- The panel should have expertise in and look at a broad range of impacts of the Doing Business tools not just their impact on growth or economic activity. This should include examining their impact on labour standards, taxation, gender, and the improved participation of marginalised groups such as poor and small-scale entrepreneurs in the economy.
We look forward to your response to this letter and would be delighted to work with you to make this review successful, which we believe could bring better outcomes for people living in poverty.
Director of CAFOD (member of Caritas Internationalis)
On behalf of the following organisations:
Bretton Woods Project
Center of Concern
KOO- Koordinierungsstelle der Österr. Bischofskonferenz f. internationale Entwicklung und Mission, Austria
Save the Children
ITUC – International Trade Union Confederation