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Bridging the UN Accountability Gap to Beneficiaries.

17 July 2023

By Katja Hemmerich


The implementation of WFP's Protection & Accountability Policy and UN Accountability.


a group of children in a international country

As we’ve highlighted before, international organizations have formal accountability structures to member states, their ‘principals’ who delegate the authority and provide funds for international organizations to fulfill their mandates. This, however, creates an accountability gap vis-a-vis the affected communities that international organizations are meant to assist and serve.


This week, the WFP Executive Board receives its annual update on the implementation of WFP’s Protection and Accountability Policy, a policy and process that starts to bridge this inherent accountability gap.


Our spotlight this week looks at WFP’s Protection and Accountability Policy and other tools used by different international organizations to establish accountability to their beneficiary communities.


The WFP Protection and Accountability Policy was initially focused on humanitarian protection and was updated in 2020 to explicitly recognize that WFP “is required to prevent and respond to protection risks associated with hunger and WFP programmes in all contexts and to craft successful protection outcomes for affected populations.” The policy takes a strong rights-based approach in line with protection standards of the Inter-Agency Standing Committee (IASC) while operationalizing the UN principle of “leaving no one behind”.


Beyond recognizing that affected people are rights-holders, it emphasizes that they must participate in the design and implementation of assistance programmes. More than just requiring consultation, the Policy requires ongoing two-way feedback mechanisms to be set up with affected populations so that they are engaged throughout implementation of programmes. Community engagement is stressed not only to enhance protection of affected populations but also to:

  • improve the quality and performance of programmes,

  • build trust in WFP and acceptance of its programmes by communities, and

  • enhance safety of both affected populations and WFP personnel.


By recognizing the positive performance outcomes for the organization in addition to the human rights prerogatives, WFP’s Protection and Accountability Policy simultaneously addresses concerns of donor and recipient countries, both of whom are represented on the Executive Board.


The requirement to report annually to the Board establishes an annual governance level discussion at which WFP’s senior management and member states can consider feedback from affected programmes. The transparency facilitated by WFP's Board - which posts virtually all documents it considers - also allows civil society and other external actors to access the same data and information as board members and use that in their monitoring or advocacy work. All of this facilitates more informed discussions and decision-making on how WFP should be working with and for affected communities.


At this year’s briefing, given the recent expansion of the policy and supporting guidance to encompass protection in all programme areas, the focus is on the establishment of policy implementation processes, including setting up of feedback mechanisms in country offices (currently in 73%), and adaptation of staff learning programmes (e.g. creation of seven new e-learning programmes). As feedback mechanisms are implemented, it is likely that more substantive discussions will take place on concerns raised by beneficiaries.


Legal scholars analyzing similar policies from an accountability perspective tend to highlight the lack of a specific complaints mechanism accessible to beneficiaries or the lack of redress mechanisms when an international organization has not fulfilled its protection responsibilities.


"[International organizations] have typically engaged in what the International Law Association (‘ILA’) has identified as ‘first level’ accountability, including monitoring and procedures, rather than ‘second’ or ‘third’ level work, such as establishing remedies for torts or breaches of international law and human rights." – K.Boon & F. Mégret, New Approaches to the Accountability of International Organizations, International Organizations Law Review, (2019)


However, scholars studying the performance of international organizations have found a positive impact of these ‘first level’ accountability mechanisms on performance. Participation mechanisms, monitoring of policy compliance by management and oversight mechanisms, as well as evaluation of policy implementation all contribute to better performance by international organizations “by stimulating bureaucratic learning, promoting more rational and balanced decision-making, and improving policy compliance.” (Ranjit Lall, Making International Institutions Work: The Politics of Performance, pg. 248)


There is a surprising variance in beneficiary-focused accountability mechanisms, which may also account for difference performance levels. Thirty years ago, the World Bank set up its Inspection Panel to allow citizens or third parties to file a complaint about the negative impact, or potential negative impact, of a bank funded project. Most multilateral development banks have followed suit, but often their focus is predominantly on environmental or social issues and they are less explicit about protection or human rights issues, which have been perceived as ‘political interference’.


"In one memorable anecdote, an economist from the Inter-American Development Bank (IADB) recounted how an access-to-information request regarding a Brazilian infrastructure project co-financed by the institution led to the discovery of a dangerous engineering miscalculation, forcing the contracted construction firm to frantically redraw its blueprints in a matter of hours. “If we didn’t have a disclosure policy,” the official reflected, “we simply wouldn’t have caught the error. The project could have been an environmental and humanitarian catastrophe." – Ranjit Lall, Making International Institutions Work, pg. 267


Underpinning the ability for third parties and citizens to complain are the banks’ public access to information policies, meaning host country governments, and often individual citizens or civil society groups are able to request all the banks’ internal information about a project in their community. This allows complainants to present a stronger evidence-based case for a thorough review by the Inspection Panel, and increases the likelihood of problems being found, as illustrated in the anecdote above.


Very few UN entities have such Inspection Panels, accessible to the public, or even access to information policies. This is what makes UNDP’s Social and Environmental Standards, and its related complaints mechanism quite unique. The standards were initially adopted in 2015 and updated in 2021, in part to explicitly link them to human rights standards and the principle of leaving no one behind. Organizations can request information about stakeholder complaints and how they were resolved, but thus far, very little actual data on implementation of the standards and the complaints mechanism is available on the UNDP website.


Nevertheless, both UNDP and WFP’s approaches to accountability to their beneficiaries present interesting examples of what is feasible in the UN context with the full support of their member states. It will be interesting to see how the discussions with the Boards evolve and the longer term impact on organizational performance as compared to other UN entities without such beneficiary-focused accountability mechanisms.


To help facilitate an informed discussion at the WFP Executive Board briefing this week, we suggest the following questions for participants to consider:


  1. What are the main types of feedback collected by the Country Offices with such mechanisms in place?

  2. What feedback have they found the most challenging to address?

  3. How is feedback from beneficiaries shared with the UN Country Team, and is the UNCT able to use this feedback?

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