Bangladesh - Independent Evaluation Group - World Bank

helped to strengthen the accounting and audit profession. The Bank also supported these and
other objectives through economic and sector work (ESW), including an Investment Climate
Assessment (2008), a Pharmaceutical Competitiveness report (2008), and technical
assistance on pricing reforms in oil and gas (2006). 16
3.37 Relevance. The World Bank’s support to improving the investment climate was a
highly relevant response to policy, regulatory, financing, and infrastructure constraints that
hampered the private sector. Streamlining tax and customs administration, expanding the
private banking network, better management of the container terminal, and streamlining
processes at the Board of Investment, Export Processing Zone Authority, and Registrar of
Joint Stock Companies were all relevant responses to facilitate trade and investment.
Project-Level Relevance
3.38 Since the 2006-09 CAS was adopted, the Bank has taken a number of steps to
strengthen GAC responsiveness across the portfolio. These were motivated by a regional
approach taken following the India Detailed Implementation Review (DIR) and reflected its
findings. In addition, it reflected a long-standing commitment from 1996 with the first of
two country governance assessments and a desire to heighten fiduciary processes as a step
toward building stakeholder support for major increases in the Bank’s lending. The measures
include strengthening the operational risk management framework, appointing a senior
governance advisor to the Country Office, and heightening demand for good governance
measures within projects.
3.39 Operational Risk Management Framework. First, the Bank’s country team set up
an Operational Risk Mitigation Team to guide the process of implementing a rolling
Operational Risk Mitigation Action Plan (ORMAP) to manage risk systematically throughout
the portfolio. The ORMAP consisted of a systematic analysis of corruption risk through
analytical work and heightened attention during project preparation, smart project design,
stronger supervision, more rigorous identification of red flags, and enhanced information
disclosure. A shortcoming is that in the case of the Padma Bridge, the largest project
currently being implemented by the government, and the largest International Development
Association (IDA) project in the country, no Governance and Accountability Plan (GAAP)
was prepared during three years of project preparation until it was recommended by the
Integrity Unit (INT) at the Operations Committee meeting —although there were fiduciary
measures and risk mitigation actions in the procurement framework that had been developed
during implementation that were later given a special focus and strengthened in the separate
GAAP . This initial omission of a GAAP raises concerns given evidence of corruption in the
Ministry of Communications. A more general shortcoming was that many risk mitigation
measures took effect after project effectiveness, thereby exposing the project to risks of
inappropriate advance procurement and mobilization payments to contractors. Furthermore,
plans to use supervision consultants hired by the government agency risked undermining
16 Although the IFC is not being evaluated here, it played an important complementary role to IDA support for
investment climate reforms, mainly through a DfID trust fund, BICF, to provide advisory services on improving
business regulations, enhancing economic zones, and building capacity through, among other things, public
private consultative forums.
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