At the IMF, there is one set of ethics guidelines for the rank-and-file staff and another for the 24 elite executive directors who oversee the powerful organization.
Over the past four years, the fund has tightened up internal systems for catching ethical misconduct among its 2,400 staff members, establishing a telephone hotline for complaints like harassment, publishing details of complaints in an annual report and empowering an ethics adviser to pursue allegations, which last year led to at least one dismissal.
However, the fund’s board members remain largely above these controls. The ethics adviser, for example, is not able to investigate any of them. The board is responsible for policing its own directors as well as the managing director. It has a five-person ethics committee, whose work is confidential. And the only way the board can discipline its members is to write a warning letter to them or to their home countries, or the group of countries that appointed them.
“There are a lot of controls in place when it comes to the staff, but not for the leadership,” said Katrina Campbell, a compliance and ethics expert at Global Compliance.
The IMF’s ethics policy has come under intense scrutiny in recent weeks since the arrest of former IMF managing director Dominique Strauss-Kahn, on charges of sexually assaulting a hotel housekeeper in New York. Strauss-Kahn, who denies the charges, has resigned his position at the fund.
In 2008, Campbell carried out a study of the IMF’s ethics policies for the its Independent Evaluation Office. It found that the board lacked satisfactory procedures for disciplining its own members or the managing -director for ethical lapses.
The report criticized the board’s code of conduct as vague, saying that it “reads, for the most part, as a set of recommendations, rather than rules” and that the board lacked effective enforcement procedures.
In contrast, it praised the staff code of conduct as detailed and offering “a plethora of policies and procedures.”
However, when Strauss-Kahn was selected for the top spot in November 2007, the staff code of conduct was written into his contract, Campbell said, although ultimately he remains answerable only to the board.
In 2008, not long after Strauss-Kahn assumed the top post, the IMF was compelled to investigate him for having an affair with a staff subordinate. In that case, the fund hired an outside law firm to handle the inquiry because the ethics officer was not authorized to investigate at that high level. Although Strauss-Kahn was found not to have abused his position, he was publicly reprimanded for showing poor judgement, and he apologized.