UNCAC Coalition and members sign letter to World Bank on corporate transparency

8 June 2015.

Dr. Jim Yong Kim
President, The World Bank
1818 H St., N.W.
Washington, D.C. 20433

Dear President Kim:

We, the 107 undersigned civil society organizations, are writing you to urge the World Bank to increase the transparency and accountability of World Bank-funded procurements, in particular by requiring the disclosure and publication of the beneficial ownership information for all legal entity bidders.

The manner in which governments conduct procurements has a direct impact on the Bank’s twin development goals of ending extreme poverty and increasing shared prosperity. Done properly, procurement allows governments to provide high quality goods, works, and services that better people’s lives by improving health, education, and economic outcomes. Sound procurement practices also create an enabling environment for strong economic growth. Done wrong, procurement can result in substandard goods, works, and services being purchased at inflated prices and can impede progress on development outcomes.

Transparency is a key feature of a well-designed procurement system.[1] The Bank itself has recognized the importance of transparent procurement, including by helping develop and promote transparent e-procurement systems in borrower countries and launching a global program to encourage adoption of open contracting. The Bank has argued that transparent procurement systems increase competition, foster citizen engagement, and reduce corruption, all of which help to ensure that procured goods, works, and services are high quality, competitively-priced, and correspond to actual public needs.[2]

In 2012, the World Bank began an important effort to reform its procurement policies. After two rounds of consultations, this process is drawing to a conclusion, with new policies expected to be approved by the Board this summer. In addition to the new policies, the Bank will also be developing new procurement regulations designed to put the new policies into practice. These new regulation s are expected to take effect in January 2016. As part of these new procurement regulations, we urge the Bank to require that all legal entity bidders on Bank-funded procurements disclose their beneficial ownership information and that the Bank publish this information in an open data format as part of its wider efforts to foster transparency in its own contracting practices.

Beneficial ownership transparency is a critical component of transparent procurement. Often, government contracts are awarded to family members, friends, or associates of the public officials overseeing them. Connected bidders and government officials may disguise their identity or that of their family members or associates behind a front or an anonymous company. By requiring that all legal entity bidders disclose information on the real people who own or control them (often called “beneficial owners”) and then publishing this information, the Bank would be foreclosing one of the most common corruption schemes that enables bidders to hide their conflicts of interest[3] and government officials to illegally enrich themselves. As found by the Bank’s Stolen Asset Recovery Initiative, opaque corporate structures were used in more than seventy percent of grand corruption cases.[4]

Countries and organizations have already recognized the need for beneficial ownership transparency in order to combat the use of anonymous companies to facilitate corruption, money laundering, illicit financial flows, and kleptocracy. The United Kingdom, Denmark and the European Union have all either taken action or pledged to take action to create beneficial ownership registries. The G20 countries have also committed to increase the transparency of legal entities by endorsing the High Level Principles of Beneficial Ownership Transparency.

By publishing the beneficial ownership information of all legal entity bidders on Bank-financed procurements, the Bank will send a strong message about the importance of transparency and further the very development outcomes it is seeking to achieve. Furthermore, the impact of such a reform will extend beyond Bank-funded projects as the Bank’s policies are often adopted by other international financial institutions as well as by borrower countries. The Bank has an opportunity to play a leadership role on this important issue, and we urge the Bank to take strong action in favor of transparency of contracts and in contracting and against anonymous companies.


  • 11.11.11 – Coalition of the Flemish North – South Movement (Belgium)
  • Access Info Europe
  • Accountability Counsel
  • Advocacy for Principled Action in Government
  • Alliance for a Just Society (US)
  • Alyansa Tigil Mina (Philippines)
  • American Jewish World Service
  • Asociación para una Sociedad más Justa (Honduras)
  • Bank Information Center
  • Bretton Woods Project (UK)
  • Center for Effective Government (US)
  • Center for International Environmental Law (US)
  • Center for International Human Rights, Northwestern University School of Law
  • Centre for Budget and Governance Accountability (India)
  • Centre for Transparency Advocacy (Nigeria)
  • Centre National de Coopération au Développement, CNCD-11.11.11 (Belgium)
  • Chile Transparente
  • Christian Aid
  • Chulachuli UNESCO Club (Nepal)
  • Conseil National des Ong de la République Démocratique du Congo
  • CorruptionWatch Aruba
  • Costa Rica Integra
  • EarthRights International (US/Peru/Thailand)
  • EG Justice (Equatorial Guinea)
  • Enough Project (US)
  • Fair Share (US)
  • Financial Accountability and Corporate Transparency Coalition (US)
  • Financial Transparency Coalition
  • Fiscal Justice Network – Latin America and the Caribbean
  • Friends of the Earth US
  • Fundación Nacional para el Desarrollo (El Salvador)
  • Fundar, Center for Analysis and Research (Mexico)
  • Global Financial Integrity
  • Global Integrity
  • Global Organization of Parliamentarians Against Corruption
  • Global Witness
  • Government Accountability Project
  • Gram Bharati Samiti (India)
  • Groupe d’Appui aux Exploitants des Ressources Naturelles (Democratic Republic of Congo)
  • Human Rights Watch
  • Integrate: Business and Human Rights (Australia)
  • International Accountability Project
  • International Budget Partnership
  • International Network on Displacement and Resettlement
  • iSolon.org
  • Jubilee Australia
  • Jubilee USA Network
  • Just Foreign Policy (US)
  • Kenyans for Tax Justice
  • Main Street Alliance (US)
  • MiningWatch Canada
  • Natural Resource Governance Institute
  • New Rules for Global Finance Coalition (US)
  • ONE Campaign
  • Open Contracting Partnership
  • OpenCorporates
  • OpenTheGovernment.org
  • Oxfam
  • Pakistan Institute of Legislative Development and Transparency
  • Participación Ciudadana (Dominican Republic)
  • Proética (Peru)
  • Project on Government Oversight
  • Publish What You Fund
  • Publish What You Pay
  • Publish What You Pay Australia
  • Publish What You Pay UK
  • Publish What You Pay US
  • Responsible Sourcing Network (US)
  • Save the Children
  • Sherpa (France)
  • Socio-Economic Rights and Accountability Project (Nigeria)
  • Sunlight Foundation (US)
  • Tax Justice Network
  • Tax Justice Network – Africa
  • Tax Justice Network – Australia
  • Tax Justice Network – USA
  • Tax Research UK
  • Towards Transparency
  • Transparencia Mexicana
  • Transparencia por Colombia
  • Transparencia Venezuela
  • Transparency International
  • Transparency International Australia
  • Transparency International Bangladesh
  • Transparency International Canada
  • Transparency International Fiji
  • Transparency International France
  • Transparency International Germany
  • Transparency International India
  • Transparency International Indonesia
  • Transparency International Italy
  • Transparency International Japan
  • Transparency International Mongolia
  • Transparency International New Zealand
  • Transparency International Panama
  • Transparency International Papua New Guinea
  • Transparency International Rwanda
  • Transparency International Turkey
  • Transparency International Uganda
  • Transparency International United Kingdom
  • Transparency International USA
  • Union Aid Abroad – APHEDA
  • United Methodist General Board of Church and Society
  • United Nations Convention Against Corruption Coalition
  • United States Public Interest Research Group
  • Uniting Church in Australia, Synod of Victoria and Tasmania
  • Water Governance Institute (Uganda)
  1. Publishing Government Contracts Addressing Concerns and Easing Implementation, Center for Global Development, 2014
  2. See, e.g., Georgia: An E-Procurement Success
  3. Public Procurement: costs we pay for corruption, PricewaterhouseCoopers, 2013, Pages 7 and 8
  4. Stolen Asset Recovery Initiative, The Puppet Masters: How the Corrupt Use Legal Structures to Hide Stolen Assets and What to Do About It, 2011