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Universal Rights or a Universe unto Itself?
Indigenous Peoples' Human Rights and the World Bank's Draft Operational Policy 4.10 on Indigenous Peoples
November 2001

Fergus MacKay
Forest Peoples Programme



Contents
Executive Summary
I       Introduction
  A   The World Bank and Human Rights: International Concern
  B   Rights-Based Approach to Development
  C   International Attention to Indigenous Peoples’ Human Rights
II       Development and Human Rights: The Role and Attitude of the World Bank
III     Does the Bank have a Legal Obligation to Respect Human Rights?
  A   The Bank’s Mandate and Articles of Agreement
    1        Position of the Bank’s Articles in International Law
    2        The Prohibition of Political Interference
    3        Only Economic Considerations
    4        Indigenous Peoples’ Rights and the Political-Economic Test
    5        Conclusion
  B   The Legal Obligations of the Bank to Respect Human Rights
    1        The Obligations of the Bank as a Subject of International Law
      (a)   Sources of Law
      (b)   Responsibility
      (c)   The obligations of the Bank vis-à-vis the human rights obligations of its members
    2        The Obligations of the Bank as a Specialized Agency of the United Nations
    3        Sustainable Development
    4        Conclusion
IV     OP 4.10 and Indigenous Peoples’ Human Rights
  A   Background
  B   The Policy Itself
    1        Land and Resources – OP 4.10, paragraphs 12 and 13
   

2        Consent, Participation and Consultation

    3        Involuntary Resettlement
V       Concluding Remarks


With regard to rules of international law other than treaties, the [International Court of Justice] has similarly recognised that international organisations are subject to the rules and principles of general international law. … What this means in practice is that the organisation should, in the conduct of its activities, be assumed to be subject to rules of customary international law, including any rules of jus cogens, which may be relevant to the conduct of its activities. In our view this would include, for example, rules of customary law relating to matters such as the protection of fundamental human rights, the protection of the environment and the conduct of activities in maritime areas and in outer space. In relation to human rights one commentator has stated the position as follows:

“The Universal Declaration and the International Covenants represent minimal standards for all people and all nations. Intergovernmental organisations are inter-state institutions and they too are bound by the generally accepted standards of the world community.”

This view appears to be unimpeachable. … Thus, notwithstanding the fact that an international organisation is not a party to, say, a human rights treaty or an agreement for the protection of the environment, if a rule contained in an agreement is reflected in customary international law then it can, as such, bind an international organisation. It has been suggested, for example, that the World Bank is not subject to general international norms for the protection of fundamental human rights. In our view that conclusion is without merit, on legal or policy grounds, even if it may be the case that certain bodies charged with reviewing the legality of acts of the World Bank, such as its Inspection Panel, are not permitted to have recourse to such law in determining whether the Bank is acting in compliance with its obligations.

Bowett’s Law of International Institutions, 5th Edition, P. Sands & P. Klein (eds.), Sweet & Maxwell, London, 2001, at p. 458-59.


Executive Summary

This discussion paper addresses two primary issues: first, whether the World Bank has legal obligations to recognize and respect international human rights, and, if so, what is the nature and extent of those obligations; and, second, whether the most recent draft of the Bank’s Operational Policy on Indigenous Peoples complies with international human rights standards and guarantees, particularly on Indigenous peoples’ rights to lands, territories and resources, to participate in decision-making and consent to activities that affect them and to be free from involuntary relocation. The two issues are closely related as an obligation of the Bank to account for and respect human rights also applies to its internal policies, at least those that may affect human rights.

On the first issue, it concludes that the Bank does have international legal obligations to account for and respect human rights and that these obligations apply both to its internal policies and to its external operations, such as loans and structural adjustment programmes. These obligations derive primarily from the Bank’s status as a subject of international, from its status as a specialized agency of the United Nations and from its status as a forum for the collective action of its members. The Bank is bound as a subject of international law to comply with rules of customary international law, with rules of jus cogens, and to ensure that it neither facilitates nor aids its members to violate the latter’s international obligations contained in ratified human rights instruments and general international law. The Bank is internationally responsible for imputable breaches of these obligations.

This conclusion is contrasted with the position of the Bank, particularly as set forth by its former General Counsel, that holds that the Bank’s constitutional instrument, its Articles of Agreement, is at the pinnacle of the international legal order applying to the Bank. While the Bank asserts that its operations contribute to the enjoyment of economic, social and cultural rights, it maintains that its Articles prohibit even discussion of human rights labeled as political rights. Pursuant to its Articles it further maintains that it not only has no obligation to respect human rights, but that it is legally precluded for addressing many human rights at all.

This paper however finds that the Bank’s Articles must be interpreted in light of contemporary international law and be subject to that law. The Bank’s Articles therefore cannot be used to justify an arbitrary distinction between different kinds of human rights, long rejected in international law, nor are they above the prescriptions of general rules and principles of law. This also applies in the case of the Charter of the United Nations and the human rights law flowing from it. While the Bank is not a party to the Charter or treaties interpreting the Charter’s human rights provisions, it nonetheless has concrete obligations derived from both and these obligations supercede its Articles. The Bank is required to respect the hierarchically superior authority of the Charter’s human rights provisions by acting consistently therewith. This duty to respect would also apply to the Universal Declaration of Human Rights and, to a lesser extent, the Covenants and other UN human rights instruments as authoritative interpretations of the Charter’s human rights provisions.

With regard to the compatibility of the draft Operational Directive on Indigenous Peoples, the paper concludes that the draft policy is clearly sub-standard in human rights terms and fails to account for and respect Indigenous peoples’ rights binding on the Bank. In particular, the policy conflicts with a number of principles of customary international law protecting Indigenous land and resource rights, rights to be free from involuntary resettlement and to participate in and consent to activities and decisions that may affect Indigenous peoples. These rules of customary international law are directly binding on the Bank.

The policy is also substantially inconsistent with Indigenous peoples’ rights recognized in general human rights instruments such as the UN Covenants, the Convention on the Elimination of All Forms of Racial Discrimination and regional human rights instruments from the American and African human rights systems. These instruments represent authoritative interpretations of the UN Charter and/or sources of binding obligation for the vast majority of Bank members, obligations the Bank is bound to account for and respect. In reaching this conclusion, extensive reference is made to the jurisprudence of intergovernmental bodies charged with monitoring state compliance with human rights instruments, such as the UN Human Rights Committee and the Inter-American Commission and Court on Human Rights.

The paper concludes by offering a few suggestions on how the obligations of the Bank can be operationalized. Ideally, the Bank should adopt a general policy on human rights that will set out the framework and prescribe specific measures for addressing human rights on an institutional and operational level. Language should also be included in Operational Polices that prohibits Bank-financing of activities that contravene its members’ international human rights obligations. Implementation of this language will require screening of projects against human rights criteria and an examination of country-specific obligations. The latter could also be addressed in a range of country-specific Bank documents, such as the Country Assistance Strategy. Finally, as the Bank will have to ensure that its projects and programmes are in fact respectful of human rights, specific, enforceable and verifiable legal covenants will have to be incorporated into loan and other agreements between the Bank and its Borrowers. While this may complicate the work of the Bank and may ultimately change the way in which it does business, the preceding is not a matter of discretion for the Bank, but rather a matter of compliance with its international legal obligations.


I         Introduction

It is apparent that multilateral institutions like the Bank, the IMF and WTO need to be continuously reminded of the human rights obligations established by international law. To borrow from Asbjørn Eide, these comprise the obligations to "respect", "protect" and "fulfill". But more importantly, [multilateral institutions] must also respect and apply those standards to their own internal processes of policy formulation, or else those obligations cease to be of any import.[1]

The International Monetary Fund and the World Bank often have a decisive say in determining a State’s economic policies and priorities. The human consequences of Bank and Fund policies can be far-reaching. Yet the impression is that sufficient account has not been taken of the consequences and the human rights implications of their actions, that these are regarded as someone else’s responsibility, not the institutions’ or the economists’. The dialogue with the Bretton Woods institutions and the World Trade Organisation must, therefore, be intensified. All of the programmes and policies pursued by the IMF and the World Bank should be consistent with international human rights standards.[2]

A       The World Bank and Human Rights: International Concern

As these quotes illustrate, the relationship between World Bank (‘the Bank’) policies and operations and international human rights standards is the subject of high level international scrutiny and concern. There have even been calls by world leaders[3] and institutions such the European Parliament for amendment of the Bank’s Articles of Agreement to ensure that human rights issues are addressed.[4] The perception that the Bank’s policies and practices, both directly and indirectly, are at odds with human rights is widespread and in many respects justified. This perception is not new and dates back to the late 1960s-early 1970s.[5]

While the Bank widely publicizes what it perceives to be its contribution to the realization of economic, social and cultural rights, it openly disregards a whole range of rights that it determines to be “political” and therefore beyond its mandate as defined by its Articles of Agreement.[6] This distinction is not only arbitrary and inconsistently applied, it also runs counter to mainstream thought about the nature of human rights and attendant international obligations. Moreover, while the Bank in some cases may play a positive role in promoting economic, social and cultural rights, it has never undertaken a systematic evaluation of its operations to ascertain their impact on human rights that can support its claims, and ample evidence demonstrates that in many cases Bank policies and operations have had a negative impact on not only civil and political rights but also on the enjoyment of economic, social and cultural rights.[7] This has prompted, among others, the UN Committee on Economic, Social and Cultural Rights, the intergovernmental body that monitors the UN convention of the same name, to comment on the impact of Bank operations on human rights. In 1990, the Committee stated that

… development co-operation activities do not automatically contribute to the promotion of respect for economic, social and cultural rights. Many activities undertaken in the name of ‘development’ have subsequently been recognized as ill-conceived and even counter-productive in human rights terms. In order to reduce the incidence of such problems, the whole range of issues dealt with in the Covenant [on Economic, Social and Cultural Rights] should, wherever possible and appropriate, be given careful and specific consideration.

As a matter of principle, the appropriate United Nations organs and agencies should specifically recognize the intimate relationship which should be established between development activities and efforts to promote respect for human rights in general, and economic, social and cultural rights in particular.[8]

And again in 1998:

The Committee calls upon the International Monetary Fund and the World Bank to pay enhanced attention in their activities to respect for economic, social and cultural rights, including through encouraging explicit recognition of these rights, assisting in the identification of country-specific benchmarks to facilitate their promotion, and facilitating the development of appropriate remedies for responding to violations.[9]

The Committee has also begun to systematically question reporting states on whether they account for human rights when casting their votes at the Bank and, in the case of borrowing states, whether they have engaged in a dialogue with the Bank about human rights in their proposed projects and other interactions with the Bank.[10]

Similarly, in its Resolution 1998/12, the UN Sub-commission on Prevention of Discrimination and Protection of Minorities (as it was then called) stated that it was “Convinced of the need to re-emphasize the centrality and primacy of human rights obligations in all areas of governance and development, including international and regional trade, investment and financial policies, agreements and practices.”[11] Accordingly, this resolution “Urges United Nations agencies, including the International Monetary Fund and the World Bank, to at all times be conscious of and respect the human rights obligations of the countries with which they work.”[12] The resolution further authorized a study on human rights and international development, trade and investment, joining the Sub-commission with the Committee on Economic, Social and Cultural Rights in scrutinizing the impact of the Bank’s operations on human rights.[13] The Sub-commission and the Commission on Human Rights have also commented with concern about Bank operations in their thematic work, such as involuntary resettlement, the impact of structural adjustment policies on economic, social and cultural rights and the right to food.[14]

Read together with the statements heading this paper, the preceding quotations highlight three different although interrelated aspects of human rights concerns related to the Bank’s work: 1) the Bank’s own internal policies and their relationship to human rights; 2) the human rights impact and implications of the Bank’s operations as related to the obligations of the Bank’s members and; 3) the obligations that the Bank may have to account for human rights in its operational sphere as a institution and subject of international law. Bradlow defines the former as ‘institutional’ and the latter as ‘operational’ human rights issues.[15] Institutional human rights issues focus “on the responsibility of the IFIs to ensure that their own internal operating rules and procedures are consistent with internationally recognized human rights standards;” operational issues “pertain to the human rights impact of the IFIs’ operations in their member states,” and focus “on the IFIs’ responsibilities for ensuring that the design and implementation of their projects, programs, policies and in-country activities are consistent with internationally recognized human rights standards.”[16]

B       Rights-Based Approach to Development

Increased international scrutiny of the World Bank on human rights grounds coincides with a general trend among multi- and bilateral development actors,[17] including UN Specialized Agencies, to adopt a ‘rights-based approach’ to development or to tie their programmatic work to human rights standards.[18] The High Commissioner for Human Rights, for instance, is working with UN development agencies to “mainstream” human rights in their operations.[19] The UN Development Programme (UNDP) has explicitly adopted a general rights-based approach to development, while others such as the UN Childrens’ Fund (UNICEF) and the UN Development Fund for Women (UNIFEM) have tied their programmatic work to human rights conventions related to their mandates: respectively, the Convention on the Rights of the Child and the Convention on the Elimination of All Forms of Discrimination Against Women.[20]

A rights-based approach to development is one that explicitly ties development policies, objectives, projects and outputs to international human rights standards requiring, among others, that development be directed towards fulfilling human rights. Conversely, it is a proactive strategy for converting rights into development goals and standards. For example, health, education or land reform projects will be informed, framed by and substantially directed towards fulfilling the procedural and substantive aspects of the associated rights. In essence, this converts development goals and objectives into rights, entitlements, responsibility and accountability. This is consistent with the UN Declaration on the Right to Development proclaimed by the UN General Assembly in 1986.[21] This Declaration was adopted with only one vote against and eight abstentions.

Current discussion on a rights-based approach to development within the UN and elsewhere is not focused on the wisdom of such an approach, which appears to be generally accepted, but rather on how it can be operationalized. While the Bank has participated in some of the discussions about implementing the right to development, and maintains that its approach to poverty alleviation is aimed at realizing economic, social and cultural rights, it has been conspicuously absent from the larger discussion about adopting a rights-based approach to development.

C       International Attention to Indigenous Peoples’ Human Rights

The human rights of Indigenous peoples have also been the subject of high level international scrutiny and action in recent years, both generally and specifically in connection with the Bank’s activities and policies. Indeed, it would be accurate to say that Indigenous peoples’ rights have become a large and permanent part of the intergovernmental human rights agenda in the past twenty years during which time international standards have evolved and strengthened considerably. This is true both for international standard setting exercises leading to or resulting in formal instruments on Indigenous rights,[22] and incorporation of some of those rights in international instruments on environment and development,[23] as well as for protection of Indigenous peoples’ rights under human rights instruments of general application.[24]

These changes at the international level have prompted, and to a lesser extent reflected, a multitude of Constitutional, legislative, jurisprudential and policy changes at the domestic level.[25] Taken in their totality, this evolution of juridical thought and practice has led many to conclude that some Indigenous rights have attained the status of customary international law and are therefore binding on states irrespective of whether they have ratified the relevant treaties.[26] Professor Siegfried Wiessner, for instance, concludes that state practice and opinio juris permit the “identification of specific rules of a customary international law of indigenous peoples.”[27] These rules relate to the following areas:

First, indigenous peoples are entitled to maintain and develop their distinct cultural identity, their spirituality, their language, and their traditional ways of life. Second, they hold the right to political, economic and social self-determination, including a wide range of autonomy and the maintenance and strengthening of their own systems of justice. Third, indigenous peoples have a right to demarcation, ownership, development, control and use of the lands they have traditionally owned or otherwise occupied and used. Fourth, governments are to honor and faithfully observe their treaty commitments to indigenous nations.[28]

Whether some Indigenous rights have attained the status of customary international law is an important issue as it relates to the human rights obligations of the Bank and its members.[29] However, it is not by itself determinative of the existence of obligations as the jurisprudence of the Human Rights Committee,[30] the Committee on the Elimination of All Forms of Racial Discrimination,[31] the Committee on Economic, Social and Cultural Rights, the Inter-American Commission of Human Rights and others have all firmly established that Indigenous rights and corresponding obligations exist under the general human rights instruments that fall within their respective areas of competence. While the Bank is not party to any of these instruments, its status as a subject of international law and as a member of the UN family confer a number of obligations with regard to the rights set forth therein and human rights in general.[32]

The Bank has previously acknowledged that Indigenous peoples require special attention as they are especially vulnerable to negative effects caused by Bank-funded operations.[33] To account for this, the Bank has adopted a number of policy statements that attempt to provide safeguards for Indigenous peoples. In 1991, for instance, it adopted Operational Policy 4.20 on Indigenous Peoples (OD 4.20). The stated broad objective of OD 4.20 is, “to ensure that the development process fosters full respect for [Indigenous peoples’] dignity, human rights and cultural uniqueness” (para. 6). This statement is also found in paragraph 1 of the draft Operational Policy 4.10 on Indigenous Peoples (March 2001), a revision of OD 4.20. In principle then, Bank policies and activities should be informed by, account for and respect Indigenous peoples’ human rights.

This paper examines one intersection of human rights issues and World Bank activities: how the Bank’s draft Operational Policy 4.10 on Indigenous peoples (OP 4.10) compares to international human rights standards pertaining to Indigenous peoples. This analysis is framed by a larger discussion on whether the Bank has international legal obligations - especially the nature and extent of those obligations - to account for and respect Indigenous peoples’ human rights in its policy setting and operational processes. I begin with a brief look at World Bank’s attitude towards human rights and their role in the development process.


II        Development and Human Rights: The Role and Attitude of the World Bank

The Bank has no formal, written policy on human rights, either in terms of the Bank’s role, or lack thereof, in promoting and requiring respect for human rights in its operations or internally in terms of its policies. OD 4.20 on Indigenous Peoples is the only operational policy that explicitly mentions human rights and the Bank has never officially stated its understanding of the term ‘human rights’ in that directive. Consequently, attitudes towards human rights have to be deduced from statements of Bank officials, its publications and practices. From this we can see that the Bank has progressed from outright rejection of human rights in the 1960s to cautious engagement in a few, defined areas. However, this engagement is still qualified by an arbitrary distinction between rights of a political nature and rights related to economic or social well-being.

In recent years, the Bank has been more forthcoming about what it perceives its role to be in promoting human rights and the place of human rights in overall development and poverty reduction efforts. In his 1999 Proposal for a Comprehensive Development Framework, for instance, the President of the Bank stated unequivocally that “Without the protection of human and property rights, and a comprehensive framework of laws, no equitable development is possible.”[34]

This statement is consistent with a review of what is considered consensus among development actors, multi- and bilateral, conducted by the Development Assistance Committee of the Organisation for Economic Co-operation and Development (OECD).[35] The OECD review stated that “To achieve sustainable development, it is necessary to address economic and financial issues on the one hand, with structural, social and human issues, on the other, in a balanced way, thereby integrating to following key elements: …Good governance and public management, democratic accountability, the protection of human rights and the rule of law ….”[36]

Similarly, the Copenhagen Declaration on Social Development and Programme of Action, adopted by states at the World Summit for Social Development, provides that sustainable and equitable development must include democracy; social justice; economic development; environmental protection; transparent and accountable governance and; universal respect for, and observance of, all human rights.[37]

The most comprehensive statement of what the Bank considers its role to be in promoting human rights is found in the 1998 Bank publication entitled, Development and Human Rights: The Role of the World Bank. Therein that Bank stated, among others, that:

  • The World Bank believes that creating the conditions for the attainment of human rights is a central and irreducible goal of development;[38]
  • The world now accepts that sustainable development is impossible without human rights;[39]
  • It is not, therefore, economic reform lending that should raise concerns about human rights, but rather, how those programs are implemented, and what measures are taken to ensure that the needs of the poor are not neglected.[40]
  • It is clear that a growing feature of poverty is the dramatic inequalities in access to the prerequisites of economic growth: education, health care, credit and basic financial services, land and knowledge. Such disparities signal problems of more profound distortions, manifested in the exclusion from public services of women, ethnic, religious and racial minorities, and geographically isolated communities. This social exclusion can lead to social instability and, all too often, to violence.[41]
  • No human rights can be guaranteed without a strong, accessible, and independent judiciary. The Bank has long recognized the importance of open and efficient courts to sustained and widely shared economic growth: contracts must be enforced, property rights must be protected, and foreign and domestic investors must have confidence in the legal security of their investments.[42]
  • Property is the ultimate potential asset of every poor person. It is the foundation upon which citizens participate in community and political life. When poor people own property in a secure and recognized fashion, they are more likely to attend school, seek medical care, invest in land, protect the environment, and build social harmony. Unfortunately, because of ill-defined institutions and inefficient, burdensome, and often corrupt bureaucratic systems, many of the world’s poor are prevented from fully realizing the value of their property. The main problem in developing countries is that property claims by the poor, while acknowledged within the community, are too often not recognized by the state. As a result, these informal owners, who account for more than 50 percent of the poor, lack access to the social and economic benefits that secure property rights provide.[43]

These statements clearly show that the Bank, albeit through the lens of poverty reduction, has in principle accepted that human rights are fundamental to development and that it does have a role to play in promoting, and through its good governance programs enforcing, human rights. Property rights, participation rights, special measures for excluded persons and groups and judicial guarantees are all identified as fundamental to poverty reduction, the primary goal of the Bank. Nevertheless, even though these recent statements are a marked improvement over the previous position of the Bank, they do not address the more fundamental issue of whether the Bank has an obligation to respect, promote and protect human rights.


III       Does the Bank have a Legal Obligation to Respect Human Rights?

This broader issue - whether the Bank has legal (as opposed to moral) obligations to respect human rights - turns largely on the legal interpretation given to the Bank’s Articles of Agreement and its Relationship Agreement with the United Nations[44] and; an examination of the status or position of the Bank in the international legal system and whether a duty to account for and respect human rights attaches to such status. In other words, is the Bank prohibited from or limited in some way from addressing and accounting for Indigenous peoples’ and other human rights by its Articles and; is the Bank a subject of international law with rights and duties arising thereby and, if so, what is the nature and extent of those duties as they apply to human rights?

A       The Bank’s Mandate and Articles of Agreement

The primary justification made by the Bank for not directly addressing the full range of international human rights in its policies and operations is its limited mandate as defined by its Articles of Agreement. This is perhaps best expressed by the former General Counsel of the Bank, Ibrahim Shihata, who stated

There is the need to honour the charter of each organization and to respect the specialization of different international organizations as reflected in the statutory requirements of their respective charters. Such is the case, in particular, with the charters of specialized UN agencies, such as the World Bank, which delimit the mandate of each organization;[45]

and,

For any international financial institution, such as the World Bank, the question becomes, not whether human rights are relevant to development, but whether the mandate of any institution, as defined and limited by its Articles of Agreement, can cover the promotion and protection of all human rights, or is limited to the rights which have an economic or social character as opposed to a political character.[46]

In essence, Shihata maintains that a textual and “teleological” interpretation of the language of the Articles precludes Bank attention to a broad range of human rights issues.[47] Specifically, he is referring to the prohibition of interference in the “political affairs” of Bank members and the requirement that only “economic considerations” are of relevance to the Bank’s decision-making processes and operational activities (respectively, Article IV, sec. 10[48] and Article III, sec. 5(b)).[49] Pursuant to this, the Bank maintains that it is only authorized to deal with the economic aspects of development and is compelled to leave aside issues that may be defined as political. In Shihata’s opinion, the political prohibition even extends to preventing the Bank’s Executive Directors from raising a state’s human rights record when debating a loan proposal.[50]

It is important to note here that the Bank’s Articles do not define the terms “economic considerations,” “political affairs” or “political character.” Subject to certain limitations, primarily those set forth in international treaty law, the Bank’s Board of Executive Directors, which has ultimate authority to interpret the Articles, is free to interpret the meaning of these terms and thus what is within its jurisdictional sphere and has done so numerous times in the past.[51] This has included issues previously defined as political and excluded by the Articles including corruption and good governance. I will return to each of these issues in greater detail below. In the meantime, it is important to understand the import of and problems with Shihata’s position and reasoning.

1        Position of the Bank’s Articles in International Law

As a number of commentators have observed,[52] Shihata’s prioritization of the Bank’s Articles places it above almost all other obligations the Bank and its members may have as members of the United Nations system[53] and as subjects of international law, and implies that any action taken pursuant to the Articles is legitimate irrespective of the prescriptions set forth in international law generally and international human rights law specifically. As concluded by a recent UN study, the effect is to turn the international legal order on its head:

The principal problem with the "honouring the charter" or "privileging the Articles" approach to the issue is that it subordinates the international human rights instruments to the charters of the agencies in question when, as a matter of law, the reverse should be the case. Human rights obligations emanate from the Charter of the United Nations and the Universal Declaration, and have come to represent a standard that in over 50 years of existence signifies a holistic approach to the human condition.[54]

The Bank does not operate in a legal vacuum; it operates within the international legal system and both it and its constituent agreement are governed by international law.[55] Neither the Bank nor its Articles are above the law; as the International Court of Justice observed, “international organizations are bound by any obligations incumbent upon them under general rules of international law….”[56] The Court has also confirmed that “an international instrument has to be interpreted and applied within the framework of the entire legal system prevailing at the time of its interpretation,” including the Charter of the United Nations and subsequently developed customary international law.[57] Additionally, Article 31(3)(c) of the Vienna Convention on the Law of Treaties provides that treaty interpretation shall take into account “any relevant rules of international law applicable in the relations between the parties.” Therefore, as a general proposition, the Bank is subject to international law and its Articles must be interpreted consistently with international legal principles, particularly those of a higher order, including human rights norms.[58]

At its 53rd session in 2001, the UN Sub-Commission on the Promotion and Protection of Human Rights made this point and more when discussing the International Monetary Fund’s contention that it was not required to respect human rights in its operations and policies:[59]

Several Subcommission Experts, including Fisseha Yimer, Yozo Yakota, Asbjorn Eide, and Paulo Sergio Pinheiro, said they were surprised to hear the IMF state bluntly that the Fund was not bound by international human rights instruments and standards. Mr. Yokota added that while the relationship between trade and financial regimes and human rights regimes was a vital issue, those regimes should not be compared on an equal footing -- human rights regimes were superior and could not be ignored even by agreements between States, or in the operations of international financial institutions.[60]

The relationship between the Bank’s Articles and the rights and duties set forth in the Charter of the United Nations is clear. Both the Bank and its members have obligations under the Charter that supercede the provisions of the Articles.[61] Article 103 of the Charter states unequivocally that: “In the event of a conflict between the obligations of the Members of the United Nations under the present Charter and their obligations under any other international instrument, their obligations under the present Charter shall prevail.” Article 1(3) of the UN Charter defines one of the primary purposes and principles of the UN to be “promoting and encouraging respect for human rights and fundamental freedoms for all without distinction as to race, sex, language or religion.” Under the heading “International Economic and Social Cooperation,” Article 55 of the Charter requires the UN to promote “universal respect for, and observance of human rights and fundamental freedoms for all ….” The UN Charter’s provisions on human rights are therefore directly relevant to the larger issue of the Bank’s responsibility towards human rights.

2        The Prohibition of Political Interference

As noted above, the prevailing interpretation within the Bank of its Articles leads to a classification of human rights issues as either economic or political; those that can be classified as economic, social or cultural rights are legitimate and cognizable, those classified as political rights are beyond the jurisdiction of the Bank. For this reason, the Bank has often highlighted what it perceives to be its contribution to furthering economic, social and cultural human rights through poverty alleviation, while disregarding the majority of civil and political rights[62] -- “For the World Bank, protecting and advancing human rights means helping the world’s poorest people escape poverty.” [63]

Apart from contradicting the accepted position that all human rights are indivisible and interdependent - a position accepted by the Bank itself - this classificatory scheme has justly been characterized as ambiguous, ad hoc, arbitrary and at times self-serving insofar as it appears that the Bank readily justifies reinterpreting its mandate to cover areas in which it wishes to operate, while arguing that it is prohibited by its Articles from those it wishes to avoid.[64] With regard to corruption, for instance, President Wolfensohn frankly stated that the Bank had decided “to redefine the word corruption, regarding it as an economic, rather than a political matter.” [65] The Bank’s position also belies the fact that almost all human rights have economic implications and most economic issues involve a series of political calculations and considerations.

Shihata defines ‘political’ as issues related to “the art and practice of running a country or governing,” but excluding “such typical economic and technical issues as the ‘management of money or the finances’ or more generally the efficient management of the countries’ resources.”[66] The Bank’s ‘good governance programmes and criteria provide more information about the scope of the latter aspect and include attention to “the manner in which power is exercised in the management of a country’s economic and social resources for development.”[67] This includes accountability (countering corruption, misuse of resources and the responsibilities of public officials),[68] transparency (access to information and participation)[69] and the rule of law (determinate and known laws, application of those laws, accessible and effective remedies, and independent, binding adjudication of laws).[70] Shihata’s legal opinions have undoubtedly greatly influenced the practice and understanding of the Bank.[71] However, other sources are equally, if not more relevant to understanding what is meant by the term ‘political affairs’.

First, in international treaty law, if the use of a term in a treaty is unclear, reference may be made to materials supplementary to the text to ascertain the intent of the drafters.[72] The record of the Bretton Woods Conference is therefore relevant to understanding the meaning of this term. Bradlow notes that the record of the Conference indicates that the purpose of the political prohibition was to ensure that the Bank’s decision making processes and operations were conducted impartially without reference to the political character of the state or states involved.[73] Consistent with this, James Paul states that “The clause, which is now Article IV(10), was drafted to assure the USSR and other socialist states (e.g., Yugoslavia) that the Bank would not meddle with their political systems.”[74] This is a far cry from the wholesale rejection of many human rights expressed by the Bank.

Significantly, the UN’s legal counsel arrived at a similar conclusion during the controversy over the Bank’s refusal to comply with calls from the UN General Assembly in 1966, and reiterated in 1967 and 1968, that the Bank refuse loans to South Africa and Portugal.[75] Responding to the Bank’s argument that the political prohibition in its Articles precluded loan refusal for reasons other than economic, the UN’s legal counsel opined that the Bank was reading this requirement too broadly.[76] In his view:

The first sentence of section 10 would appear to have as its purpose the prohibition of interference in the internal political affairs of a Member State and of discrimination against a State because of the political character of its government. He doubted very much that the sentence was intended to relate to criteria involving the international conduct of a State affecting its fundamental Charter obligations.[77]

Bleicher concurs: “The policy goals underlying article IV, section 10, should not be construed as making no distinction between ‘political affairs’ and violation of the basic legal norms of the international system.”[78] Much of the corpus of human rights law is generally considered part of the basic legal norms of the international system.

Second, the UN Charter has a similar provision prohibiting interference in internal political affairs.[79] However, it is standard and accepted practice within the UN that this provision does not apply to human rights, which are deemed of international concern and therefore not solely within the internal sovereign or political sphere of states.[80] One conclusion that can be drawn from this is that the political prohibition cannot be interpreted as encompassing human rights as the international law understanding of the term ‘political affairs’ does not include human rights and, thus, the Bank’s Articles must be interpreted accordingly.[81]

Third, as part of the exercise of their sovereign will, the vast majority of the Bank’s members have voluntarily committed themselves to abide by human rights standards through ratification of international conventions, through the formation of international customary human rights norms and, in some cases, by assenting to UN and other declarations.[82] In doing so, they have accepted international obligations to promote, respect, protect and fulfill human rights and, in many cases, international oversight of their compliance with these obligations. It is therefore extremely problematic, and contrary to accepted international practice, to characterize human rights as solely internal, political considerations, or, as the Bank often does, to characterize raising human rights issues as a violation of state sovereignty.[83] As Judge Weeramantry of the International Court of Justice observes

In its ongoing development, the concept of human rights has long passed the stage when it was a narrow parochial concern between sovereign and subject. We have reached the stage, today, at which the human rights of anyone, anywhere, are the concern of everyone, everywhere. The world’s most powerful States are bound to recognize them, equally with the weakest, and there is not even the semblance of a suggestion in contemporary international law that such obligations amount to a derogation of sovereignty.[84]

Integration of human rights issues into Bank policy setting and operational activities would, in the majority of cases, merely restate aims, objectives and obligations to which the vast majority of its members have already subscribed. In states with a monist legal system – a significant number of Bank members - these international obligations are an integral part of their domestic law; in dualist states they have been incorporated, or are required to be incorporated, into domestic law.[85] Moreover, as discussed below, the Bank has obligations under international law not to undermine its members’ ability to faithfully comply with, nor to facilitate violation by its members of, their international obligations, including those pertaining to human rights.[86]

Finally, it is relevant in this context to note that the Bank’s Operational Policy 4.01 on Environmental Assessment clearly states that “the Bank takes into account … the obligations of the country, pertaining to project activities, under relevant international environmental treaties and agreements. The Bank does not finance project activities that would contravene such country obligations, as identified during the EA” (para. 3 ).[87] OP 4.36 on Forestry also states that “The Bank does not finance projects that contravene applicable international environmental agreements.” If this is possible with regard to environmental obligations, is there a compelling reason why human rights obligations should not be accorded equal status?[88] The Bank’s Senior Counsel agrees insofar as he states that the Bank must account for its members’ treaty obligations in general:

Because governments are the owners of the institutions like the World Bank, and are bound to comply with the treaties they have ratified, multilateral financial institutions must be careful to ensure that if these treaties are implicated in their projects, the treaties are appropriately taken into account in project design and finance.[89]

3        Only Economic Considerations

According to Shihata, the language ‘only economic considerations,’ which is the other side of the political-economic dichotomy found in the Bank’s Articles, refers to only those issues that in the Bank’s judgment have a “direct and obvious economic effect relevant to the [Bank’s] work”[90] and dictates that the Bank focus exclusively on economic factors in its decision making unless non-economic issues can be shown to have a reached “such proportions as to become a Bank concern, either due to significant direct economic effects or if it results in international obligations relevant to the Bank ….”[91] Professor Paul, however, argues that “The clause was intended to enjoin use of ‘non-economic’ (e.g., ideological) criteria as grounds to determine eligibility for Bank membership or for loans, and presumably, it commands that Bank loans must be confined to the promotion of ‘economic development.’”[92]

Further, Bradlow cogently argues that as Bank projects are implemented over a relatively long time frame and are designed to produce enduring effects, “it is likely that within such a time frame almost all political, social and cultural issues will have a direct and obvious effect:”[93]

To cite an example, consider a Bank Member State that decides on human rights grounds to grant all criminal defendants the right to counsel and a fair trial. Prima facie, this decision would appear to be a political decision that is not relevant to Bank decision making. However, this decision, over time, can have significant and potentially contradictory economic effects. On the one hand, the resulting improvement in the Member State’s human rights situation could lead to an improvement in business confidence, which could result in increased investment, increased employment, and reduced social tensions. On the other hand, the decision could lead to a reallocation of resources towards the criminal justice system, which could result in a reduction of resources available to the civil justice system. The need for police officers to spend more time in court testifying in criminal trials could lead to a reduction in the number of police officers available to prevent crime. In addition, the decision could lead to a budgeting reallocation to the criminal justice system with adverse consequences for other areas of the budget. These developments could adversely affect business confidence leading to a reduction in investment, a rise in unemployment and social tensions, and a decline in the Borrower State’s ability to perform its loan obligations. In either case, it is clear that the decision will have direct economic consequences.[94]

4        Indigenous Peoples’ Rights and the Political-Economic Test

Applying the political-economic test to Indigenous peoples’ rights poses even greater difficulties. These rights are often fundamentally related to and intertwined with ownership and control of land, which is widely accepted as the basis of Indigenous political, social, spiritual and cultural organization. These rights are also intergenerational, often involving rights and duties held of and owed to previous and future generations. A UN study on Indigenous land rights, for instance, has found

(i) a profound relationship exists between indigenous peoples and their lands, territories and resources; (ii) this relationship has various social, cultural, spiritual, economic and political dimensions and responsibilities; (iii) the collective dimension of this relationship is significant; and (iv) the intergenerational aspect of such a relationship is also crucial to indigenous peoples’ identity, survival and cultural viability. There may be additional elements relating to indigenous peoples and their relationship to their lands, territories and resources which have not been captured by these examples.[95]

How does the Bank, in funding a project that affects Indigenous peoples’ land rights, separate out the economic, political, cultural, religious, and social aspects of those rights in order to determine what activities are within its jurisdictional competence? Rights to autonomy and self-government are predicated upon having a defined and recognized land base. Indigenous legal systems are fundamentally related to land and resource management and social cohesion. Security of tenure is fundamental to economic security and development opportunities as well as cultural survival. Indigenous economic activities, which are normally central to cultural identity, are in most cases based upon detailed knowledge and use of specific lands and waters. The latter clearly meets the Bank’s jurisdictional test, the former not, yet they are each inseparably associated with Indigenous territorial rights.

The same may also be said for the prohibition of racial discrimination, a fundamental component of Indigenous rights. This prohibition exists both independently and in connection with other rights. The prohibition of racial discrimination in connection with Indigenous land and resource rights is of particular relevance. Clearly, discrimination has both political and economic facets that are interdependent and Bank publications have recognized the economic costs of discrimination against Indigenous peoples as have others.[96] Yet the Bank refuses to treat Indigenous land rights as an cognizable issue instead considering the issue part of the internal political realm of states.[97]

How does the Bank extricate those elements of Indigenous cultural rights applying to economic matters from those applying to non-economic matters, when the authoritative interpreters of that culture, Indigenous peoples themselves, would find such a distinction nonsensical and impossible to apply in practice? How does the Bank address an Indigenous people who view the land as the seat of their economic and physical well-being as well as the material incarnation of an ancestor and therefore, a relative? How does one separate the right to freely pursue economic, social and cultural development from the right to freely determine political status, when each are dependent on the other? These considerations apply both to Bank operations and to the nature of safeguards provided by Bank Operational Policies, especially OP 4.10 on Indigenous peoples, but also the OPs on Forestry, Environmental and Social Assessment, Habitat protection, etc.

5        Conclusion

This section illustrates that Bank attention to human rights issues is partly a matter of the interpretation given to the language of its Articles of Agreement. The argument of the Bank, its former General Counsel especially, is that the language of the Articles precludes engagement with many human rights issues and places the Articles at the pinnacle of the legal order applying to the Bank. This position is sanctioned by the Bank’s Board of Executive Directors, which has ultimate authority to interpret the Articles. The Bank also maintains that, while it may not address all human rights, it does substantially contribute to the realization of economic, social and cultural rights and, indirectly through its governance programmes, to the realization of civil and political rights. It should be noted here again that the Bank has never engaged in an analysis of whether it has any legal obligations with regard to human rights, but rather only whether, under its Articles and as a matter of discretion, it may or should promote or condition operations on human rights considerations and if so which.

The counter argument, which I believe to be correct, states that the Bank’s Articles are not immune from the prescriptions of international law, human rights law in particular, and therefore cannot rule out attention to the full range of human rights. It also questions the prevailing interpretation of the political prohibition in the Articles and proposes alternative, and in light of contemporary international practice, more appropriate interpretations.[98] The economic-political dichotomy is presented as lacking any basis in fact that is both arbitrary and inconsistently applied. In the case of Indigenous peoples’ rights it presents substantial difficulties. Both as an international legal person and as a forum for collective action by its members, the Bank has certain defined duties concerning human rights that cannot be ignored. At a minimum, Bank policies and practices must account for and respect human rights standards and the Bank should require – as does its policy on Environmental Assessment – that it will not finance projects that contravene its members’ international obligations.

B       The Legal Obligations of the Bank to Respect Human Rights

This section of the paper looks at whether the Bank has a legal obligation to account for and respect human rights. This obligation may derive from a number of sources; two will be looked at here: the duties incumbent upon subjects of international law and the obligations pertaining to specialized agencies of the United Nations.[99] The member states of the Bank have clear obligations to respect human rights, derived from a variety of sources, that also bear upon the overall obligations of the Bank. I will begin with the obligations of subjects of international law.

1        The Obligations of the Bank as a Subject of International Law

A subject of international law is an entity capable of possessing international rights and duties as well as the capacity to bring international claims.[100] While not strictly equivalent, this can also be described as international legal personality. In the case of international organizations, international personality is normally determined by reference to their constituent instruments, either by virtue of an explicit statement conferring personality or by implication of their powers and functions.[101] The latter entails an examination of whether the attribution of legal personality is an indispensable requirement of the purposes of the organization and whether the organization was intended to exercise functions that can be explained only by possession of international personality.[102] The Bank’s Articles do not explicitly state that it has international personality, however, reference to its purposes, powers and functions clearly demonstrates that it does and I have found no disagreement with this by either the Bank or scholars.[103]

As a subject of international law, the Bank has rights and duties, separate from and in addition to its member states, defined by international law.[104] However, those rights and duties are not the same as those held by states; the latter possess the totality of rights and duties recognized by international law, whereas the rights and duties of the Bank are limited to those related to “its purposes and functions as specified or implied in its constitutional documents and developed in practice.”[105] The Bank’s purposes and functions, particularly as developed in practice, are directed towards poverty alleviation and economic development (often referred to as sustainable development), the ultimate aim of which is to improve the dignity and quality of human life. The essence of human rights is the dignity and well-being of the human person, individually and collectively. The right to development is itself a human right comprising both economic, social and cultural rights as well as civil and political rights.[106] Also, the Bank’s activities, directly and indirectly, implicate a wide range of human rights issues. Consequently, the Bank’s duties towards human rights should not be limited or excluded by the scope of its powers and functions.

(a)      Sources of Law

The Bank’s international legal obligations may be located in a number of specific sources of law: international conventions, customary international law, general principles of international law and peremptory norms of international law.[107] According to Schermers, “Apart from those peremptory norms of international law which form part of the legal order of all international organizations, further rules of international law are also applicable within international organizations …. As the latter have been established under international law, these rules of international law apply directly as part of the legal order of the organization in question obviating the need for transformation.”[108] Thus, the Bank is bound by international law with regard to both its internal and external activities and, with the exception of treaty-based obligations, these obligations pertain to the Bank without any affirmative act on its part.

International human rights law is part and parcel of international law and is expressed in conventions, customary international law, peremptory norms, international obligations erga omnes and general principles. As a general proposition then, the Bank also has obligations concerning the international law of human rights with regard to its internal and external activities. The nature and extent of these obligations in large part depends on their source, e.g., treaty, custom, peremptory norms. Beginning with treaties, the general rule of international law is that third parties are not bound by treaties without their express consent.[109] The Bank is not party to any human rights conventions and therefore is not directly bound.[110] This does not mean however that these instruments are irrelevant to the Bank’s obligations: they may restate or inform the content of binding rules of customary international law,[111] they set out the obligations of most Bank members, and they elaborate upon the human rights provisions of the UN Charter, a source of obligations for both the Bank and its members.[112]

There is no question, however, that international organizations, including the Bank, are bound by customary international law and general principles of law.[113] The International Court of Justice specifically referred to such obligations in the WHO Agreement Case.[114] The European Court of Justice has also found that the European Community is bound by international law and “is required to comply with the rules of customary international law ….”[115] Morgenstern states that:

There is no reason why rules of international law which are generally recognized as applicable between States and which are not by their nature unsuitable for international organizations should not be automatically binding on the latter. Such a conclusion has been justified on the ground that States bound by rules of international law should not be able to evade them collectively. Alternatively, if international organizations are seen as legal entities distinct from their members [possessing international personality], the applicability of the relevant rules can be explained as a necessary implication of legal capacity and activity in the international legal order.[116]

There is also no doubt that international organizations are bound by peremptory norms of international law or jus cogens.[117] These peremptory norms include the prohibition of racial discrimination, the prohibition of genocide and the right to self-determination.[118]

Related to peremptory norms is the concept of obligations erga omnes, first pronounced by the ICJ in the Barcelona Traction Case.[119] These obligations are owed by states “towards the international community as a whole.… In view of the importance of the rights involved all States can be held to have a legal interest in their protection….”[120] Obligations erga omnes derive from, among others, the prohibition of genocide and “from the principles and rules concerning the basic rights of the human person, including protection from slavery and racial discrimination.”[121] Based in part on this statement, the International Law Institute has supported the proposition that the general obligation to respect human rights is itself an obligation erga omnes.[122] While normally stated as obligations of states, it would be appropriate and logical, given their fundamental, international character, to apply obligations erga omnes to all international legal persons, especially international organizations comprised of states such as the Bank

(b)      Responsibility

Having established that the Bank does have legal obligations under international human rights law, I will now briefly touch upon the issue of responsibility in respect of those obligations. Brownlie observes that “there is no compulsory system for review of the acts of organizations by bodies external to them. In this situation the controls, such as they are, are provided by general international law. The correlative of legal personality and a capacity to bring international claims is responsibility.”[123] According to Amerasinghe, the rules of responsibility for international organizations under international law may be defined in similar fashion to the rules of customary international law applying to state responsibility.[124] International organizations, including the Bank, are thus responsible for acts and omissions imputable to them that breach their international obligations.[125] With regard to human rights law, international organizations are responsible for breaches of the obligation to respect internationally recognized human rights, primarily those characterized as customary law and jus cogens norms.[126]

In order to determine if a breach has occurred, the precise nature of the obligation must be ascertained. For analytical purposes, human rights obligations are divided into different levels each requiring a different level of commitment: positive, negative or neutral.[127] Positive obligations, such as the obligation to protect human rights and the obligation to fulfill human rights, require affirmative measures and acts in relation to both the substantive and procedural aspects of rights. The obligation to respect human rights is largely a negative obligation requiring that the obligation holder refrain from violating rights and act consistently therewith. Neutral obligations require respect for present levels of (international) legal protection attributed to a right: an obligation not to make the human rights situation worse.[128]

The obligations that attach to rules of customary international law and peremptory norms are generally negative and neutral: to act in accordance with and to refrain from violating these norms (negative), and to respect the current level of enjoyment (neutral). These obligations apply to both internal and external acts of the Bank and in the context of internal policies require that Bank policies both, account for and are consistent with customary and peremptory human rights norms. Amerasinghe states that international organizations’ responsibility for violation of obligations defined by customary international law “will be based on fault, risk or absolute liability, as the case may be, depending on the obligation and the content of the applicable customary international law.”[129]

(c)      The obligations of the Bank vis-à-vis the human rights obligations of its members

While the Bank has rights and duties separate from and in addition to its member states, the obligations of its members states are not irrelevant. On the contrary, the Bank is obliged, as is any other subject of the law, to ensure that it neither undermines the ability of other subjects, including its members, to faithfully fulfill their international obligations nor facilitates or assists violation of those obligations.[130] This duty, binding on all subjects of international law, is in part a correlative of the general principle of international law, pact sunt servanda: a treaty is binding upon the parties and must be performed in good faith.[131] The law of state responsibility is also of relevance here. Article 16 of the International Law Commission’s draft Articles on Responsibility of States for internationally wrongful acts reads:

Aid or assistance in the commission of an internationally wrongful act. A State which aids or assists another State in the commission of an internationally wrongful act by the latter is internationally responsible for doing so if: (a) That State does so with knowledge of the circumstances of the internationally wrongful act; and (b) The act would be internationally wrongful if committed by that State.[132]

The preceding adds an extra dimension to the obligations of the Bank and requires that its policies and operations account for and respect the obligations of its members under ratified human rights conventions, regional as well as universal, and other sources of law binding on them. As parties to UN and regional human rights instruments, the Bank’s members are obligated to respect, ensure and fulfill the rights set forth in those instruments. What this means in practice will vary depending on the specific obligations of the various members of the Bank and how those obligations are implicated in Bank-financed activities. On a policy level, the Bank is obliged to ensure that policy formulation and implementation account for and respect its members’ human rights obligations. Bradlow and Grossman concur: “in general, it is safe to assume that the IFIs should perform their functions in a way which supports the fundamental rights of individuals and peoples.”[133] As noted above, the Bank’s policy on Environmental Assessment provides that it will not finance activities that contravene a state’s obligations under international environmental treaties.[134] Similar language and adherence thereto in the Indigenous peoples and other policies would satisfy the Bank’s obligation at the policy level.

In summary, subjects of international law, including international organizations such as the Bank, are obliged to refrain from violating and to respect existing levels of legal protection accorded to human rights characterized as customary international law and jus cogens. These obligations apply both to the Bank’s internal and external activities as human rights principles so characterized form part of the internal and external legal order of the Bank. The Bank is internationally responsible for imputable breaches of these obligations. Human rights conventions are not directly binding on the Bank, but are relevant insofar as they restate and further develop binding sources of law. The Bank is also obligated not to undermine its members’ ability to faithfully fulfill their international human rights obligations as defined by ratified instruments and other sources of binding law and therefore must account for and respect these obligations in its policies and operations.

Prior to drawing further conclusions about the full extent of Bank obligations, the obligations of the Bank as a specialized agency of the United Nations will be discussed. In doing so, a distinction must be drawn between the obligations of Bank members separately and acting collectively through the Bank, and the obligations of the Bank as a separate legal person and specialized agency under the Charter of the UN. While these obligations are related, they are nonetheless distinct.

2        The Obligations of the Bank as a Specialized Agency of the United Nations

The Bank was created in 1944 a year prior to the establishment of the UN. Its status as a specialized agency of the UN, and the nature of the relationship between the Bank and UN, is based upon and defined by a treaty known as the Relationship Agreement.[135] This Relationship Agreement was made pursuant to Articles 57 and 63 of the UN Charter. Article 4(3) of the Relationship Agreement stresses that the Bank is an independent organization and recognizes that

action to be taken by the Bank on any loan matter is to be determined by the independent exercise of the Bank’s own judgment in accordance with the Bank’s Articles of Agreement. The United Nations recognises, therefore, that it would be sound policy to refrain from making recommendations to the Bank with respect to particular loans or with respect to the terms or conditions of financing by the Bank.

While this provision provides for a much looser association between the UN and the Bank than exists between the UN and other specialized agencies, it relates only to UN involvement in Bank-decision making processes rather than any larger responsibility the Bank may have under the UN Charter or international law in general. As evidenced by the General Assembly resolutions on South Africa and Portugal, the UN, at least in the 1960s, was of the opinion that this provision did not preclude it calling on the Bank to refuse loans due to the “conduct of a State affecting its fundamental Charter obligations.”[136] Skogly observes that, “part of the reasoning behind bringing these organizations [specialized agencies] into a formalised relationship with the UN must have been to grant them, both legally and practically, rights and obligations in relationship to the UN ….”[137] These obligations, at a minimum, include respect for the principles and purposes of the UN.

If this reasoning is correct, as a specialized agency of the UN, the Bank has obligations derived from the UN Charter, in particular to act in conformity with the Charter.[138] Lauwaars concurs stating that “Not only must the treaty establishing the organization between UN Member States be in accordance with the Charter and the obligations imposed upon the Member States by the Charter, but the decisions of the new organization itself must also comply with the Charter.”[139] This means that the Bank’s policies, internal and external, and operations must be formulated and implemented in accordance with the Charter’s provisions related to human rights. As noted above, the UN Charter stands above the Bank’s Articles. This also implies that the Bank’s Articles, particularly the interpretation given to the political prohibition, should be read consistently with the UN Charter and its human rights provisions.

The Charter’s provisions dealing with human rights are rudimentary and lack specificity. Other than self-determination, the only right explicitly mentioned is the prohibition of discrimination. Partly for this reason, in 1948, the UN General Assembly adopted the Universal Declaration of Human Rights to elaborate upon and specify the Charter’s human rights provisions and obligations. The Universal Declaration, wholly or in part, is widely considered to express general principles of international law and binding norms of customary law despite its non-binding status when adopted.[140] Subsequent codification of human rights by the UN, the International Covenants and CERD in particular, has also clarified any ambiguity in the meaning of the Charter’s provisions. Professor Sohn observes that, although the Covenants

resemble traditional international agre