Bank Guidance. Policy and Procedure Framework. Bank Access to Information Policy Designation Public. Catalogue Number LEG4.01GUID.

Transcription

1 Bank Guidance Policy and Procedure Framework Bank Access to Information Policy Designation Public Catalogue Number LEG4.01GUID.01 Issued and effective January 8, 2014 Content Guidance explaining various aspects of the Policy and Procedure Framework Applicable to IBRD and IDA Issuer Senior Vice President and WBG General Counsel Sponsor P&P Framework Administrator

2 SECTION I PURPOSE AND APPLICATION 1. This Guidance: (a) provides background to, and generally explains, the P&P Framework; (b) provides additional information on basic information to be included in each P&P Document as set out in the P&P Document Templates; (c) describes general methodology and basic techniques in drafting P&P Documents; (d) describes recommended courses of action in the management of P&P Documents; and (e) explains the role of the P&P Framework Administrator. 2. This Guidance applies to the Bank. SECTION II DEFINITIONS As used in this Guidance, the capitalized terms have the meanings set out in: (a) Section II of the P&PF Policy; (b) Section II of the P&PF Directive; (c) Section II of the P&PF Procedure; or (d) below: 1. ADM: Guidance on the Accountability and Decision-Making Framework, April, IAD: the Bank s Internal Audit Vice Presidency. SECTION III SCOPE 1. Background and General Explanation of the P&P Framework a. Background. The P&P Framework was adopted by the Bank in , in part in response to the findings of a 2012 review by IAD. 2 IAD found that the then existing approach for managing and organizing the World Bank Group s rules and guidance needed improvement, and identified the following problems: i. inconsistent definition of categories of policies and procedures; ii. iii. vague ownership and unclear approval authority; no single repository for all documents; 1 Bank Policy and Procedure Framework (R [IDA/R ]), dated July 31, 2013, approved by the Executive Directors on August 9, 2013; P&PF Policy, P&PF Directive, and P&PF Procedure. 2 Audit of WBG Framework for Policies and Procedures, (IAD Report No. WBG FY12-04), January 20, Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Page 1 of 9

3 iv. poor and inconsistent communications to staff about revisions and new policies and procedures; and v. inadequate overall management of these documents. IAD recommended that a single framework be adopted and tailored by each WBG institution in accordance with its institutional needs and business operations. The P&P Framework addresses each of these findings and recommendation. b. General. The P&P Framework establishes a uniform centralized system as a way to organize Bank rules and guidance in a more efficient, reliable and easily accessible manner. The P&P Framework itself does not prescribe the substantive content of a P&P Document, nor does it alter the existing allocation of responsibilities for developing and issuing rules and guidance. Thus, the Board and Management continue to issue rules and guidance to staff within their respective areas of responsibility in accordance with existing policies, procedures and protocols. The P&P Framework does aim to make the process more organized and efficient by creating an orderly architecture for rules and guidance. It also seeks to improve management of, and access to, rules and guidance. Finally, the P&P Framework is intended to make the articulation of Bank rules and guidance more consistent, clear and understandable. c. ADM. The P&P Framework is consistent with the ADM. The ADM sets out a framework for defining the roles played by various participants in a decision-making process within the Bank. The P&P Framework organizes the documents that instruct staff as to when these functions are performed, who performs them, and how, and ensures that P&P Documents are consistent with ADM requirements. d. Types of P&P Documents. The P&P Framework establishes a clear hierarchy of documents that are to be used to set out mandatory rules and non-mandatory guidance. The P&PF Policy requires that when the Board decides on a rule regarding conduct of institutional activities, the rule is issued as a Policy, and that when Management decides on a rule or guidance regarding conduct of institutional activities, the rule is issued as a directive or procedure, and the guidance is issued as a statement of guidance (all as elaborated by Management. These are elaborated in the P&P F Directive. Thus, the P&P Framework establishes four types of documents that govern and provide guidance with respect of the conduct of institutional activities: Policy, Directive, Procedure, and Guidance. i. Policy, Directive, and Procedure. These three types of documents are mandatory. A Policy is the highest level document. A Policy and a Directive are similar in that both contain substantive statements that require, permit or constrain activities undertaken to achieve institutional goals. The main difference between the two documents is the source from which their content is derived and normally the level of detail. The Directive is generally meant to be the more granular of the two. The Board approves a Policy; Management approves a Directive (as well as a Procedure and Guidance). A Procedure consists of procedural instructions to staff to be followed to implement a Policy or a Directive, or both. Neither a Directive nor a Procedure may contradict, or be interpreted in a manner that would contradict, a Policy or be waived or interpreted in a manner that would contradict a Policy. A Procedure is subservient to a Directive and may not contradict a Directive, or be waived or interpreted in a manner that would contradict a Directive. In some cases, a Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Page 2 of 9

4 Policy may be accompanied by both a Directive and a Procedure. However, in other cases, a Policy may be accompanied by one or the other, or even neither. Similarly, Management may issue a Directive covering matters within its authority, even if there is no accompanying Policy. Management may also issue a Procedure with instructions to be followed on carrying out a function or task not covered by either a Policy or a Directive. In certain rare instances, it may be necessary to include Directive-type provisions and Procedure-type provisions in a single P&P Document. The Document is then referred to as a Directive/Procedure. However, a Policy and Guidance are always issued separately. ii. iii. Guidance. Unlike the other three types of P&P Documents, Guidance is not mandatory. Guidance may or may not be associated with a specific Policy, Directive or Procedure. Guidance may consist of recommended courses of action, best practices, optional templates, examples, and other information to assist staff in performing various activities. Since Guidance is not mandatory, staff may choose not to follow its recommendations without the need for a waiver or formal approval process. Staff are generally expected, however, to be able to explain to their Management, if asked, the reasons for a decision not to follow the recommended actions. Of course, if such decision were to result in noncompliance with the requirements of a Policy, Directive or Procedure, it would constitute a violation of the mandatory P&P Document. Formatting; Drafting Principles. To ensure that each P&P Document contains certain critical information in a consistent format, the P&PF Directive sets out required information, and the P&PF Procedure refers to P&P Document Templates to be used for each P&P Document. This Guidance sets out additional information on the basic information required in each P&P Document (see Section III.2). To facilitate the readability of P&P Documents, this Guidance also sets out some recommended principles for drafting P&P Documents (see Section III.4). e. Development of P&P Documents i. Roles and Responsibilities. The P&P Framework sets out a clear allocation of ADM-consistent roles and responsibilities related to P&P Documents. The P&PF Policy defines the roles of Sponsor and Issuer, whose responsibilities are detailed in the P&PF Directive and P&PF Procedure. The Sponsor is responsible for preparing (or revising) the P&P Document and obtaining advice, concurrence, clearance and decision regarding the content of the P&P Document in accordance with applicable procedures and protocols. As the name implies, the Issuer is responsible for issuing the P&P Document (new or revised) once it has been finalized and approved. The Issuer is normally the approver of the P&P Document. However, in some cases, such as in the case of an operational policy, based on established Bank practice, the Issuer (Management) issues the Policy to reflect a policy proposal approved by the Board. ii. Revision of P&P Documents and Legacy Documents. A revision of a P&P Document or a Legacy Document is considered to be either a Major Revision or a Minor Revision, as these are defined in the P&PF Procedure. The P&PF Procedure describes how each type of a revision is to be processed, and whether, in the case Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Page 3 of 9

5 of a Legacy Document, the revision triggers the need to retrofit the Legacy Document (and associated documents).. iii. Plan. When preparing a new P&P Document or a Major Revision, it is recommended that the Sponsor begin with a plan covering the purpose for the new P&P Document or the Major Revision, the expected process for its preparation, approval, issuance and dissemination, the proposed consultation process, and any other relevant information. The Sponsor may include the plan as a supporting document when transmitting the new or revised P&P Document or revised Legacy Document for clearance or approval. f. Implementation Support. Once a P&P Document has been issued and is effective, the Sponsor has the primary responsibility to provide implementation support, which includes administering and interpreting the provisions of a P&P Document, reviewing it, and proposing revisions, if and when necessary. To ensure flexibility so that the conduct of Bank activities is not unduly constrained by mandatory rules, the P&P Framework allows for Exceptions (defined in the P&PF Directive) and Waivers (defined in the P&PF Policy) to mandatory P&P Documents. g. P&P Repository. The P&P Repository serves as the exclusive official repository in which all current and expired P&P Documents (as well as those Legacy Documents that are provided for the purpose) are to be published. The P&P Repository essentially functions like an official journal for the Bank of all Bank rules and guidance. A P&P Document is issued by being published electronically in the P&P Repository. A P&P Document does not become effective unless it has been published in the P&P Repository. P&P Documents are catalogued and grouped by subject, so as to make it easy for staff working on a particular matter to search the P&P Repository and have all the applicable documents in one place. Although all Guidance may be included in the P&P Repository, Guidance that is directly associated with a Policy, Directive or Procedure or is not associated with any mandatory rule but has repercussions beyond the issuing unit, is expected to be included in the P&P Repository. h. Administration of P&P Framework. The P&P Framework is managed and administered by the Legal Vice Presidency, specifically the P&P Framework Administrator, whose roles and responsibilities are set out in the P&PF Directive and P&PF Procedure, and elaborated on below (See Section III.5 below). 2. Basic Information in a P&P Document The following explains selected items required by the P&PF Directive to be included in a P&P Document, as indicated in the mandatory P&P Document Templates: a. AIP Classification. The World Bank Policy on Access to Information, July 1, 2013 sets out the various categories in which a Bank document is classified, and when one classification category or another should be used. The P&P Document includes on the title page the appropriate classification. b. Title. Under this heading, the P&P Document specifies the WBG institution issuing the P&P Document, the type of P&P Document and the name of the P&P Document. Thus, the title of the P&P Document clarifies whether it applies to one or more institutions or the entire WBG. A Directive that applies to the entire WBG is entitled WBG Directive. A Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Page 4 of 9

6 Directive that applies to one or more institutions includes the names of the institution(s) in the title. c. Purpose. Under this heading, the P&P Document sets out the objectives of, and general subject covered by, the P&P Document. d. Applicability. Under this heading, the P&P Document specifies the institution or staff within the institution to which the document applies. The P&P Document may apply to one or more institutions or the entire WBG, if the institutions decide to issue a common P&P Document. It may also apply to a group of staff within the institution. This information is included both on the title page and in the main text of the document. The title page includes only the institution(s); the main text may provide more detail if needed regarding groups of staff to which the P&P Document applies. Examples of a group of staff include: staff members holding a term appointment; procurement specialists; staff responsible for information technology; and staff responsible for treasury operations. 3. Drafting Methodology and Techniques The goal of the drafter of the P&P Document is to communicate the underlying purpose of the P&P Document and the means of achieving that purpose in a consistent, coherent, concise and clear manner. A number of commonly used techniques help in accomplishing these objectives. a. Coherent Organization. Following a clear, coherent and sequential architecture in preparing documents helps ensure that all important topics are covered comprehensively and clearly. b. Classification. Properly classifying the material to be covered under one of the four types of P&P Document (Policy, Directive, Procedure or Guidance) is essential and facilitates organizing the main and subordinate requirements in a logical manner and appropriate hierarchical order. Proper classification may involve an element of judgment. c. Sequencing of Concepts i. Once the underlying concepts and hierarchy of these concepts have been worked out, the concepts can be set out in a logical sequence. What constitutes a good sequencing of concepts and organization of provisions in a P&P Document depends on the subject, the complexity and other factors that vary from situation to situation. However, a structure that adheres to the following general principles works well in most cases: A. General provisions that apply to the entire document or a large portion of the document are stated first, followed by more specific provisions. B. Most important provisions are articulated before less important ones. C. Frequently used provisions come before less frequently used provisions. D. Permanent provisions are set out before temporary ones. E. Administrative provisions dealing with technical issues, such as effective date, revision and references to other documents, are placed at the end. Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Page 5 of 9

7 ii. The P&PF Policy, P&PF Directive, P&PF Procedure and the P&P Document Templates follow these principles by organizing P&P Documents in the following sequence: A. Purpose of the P&P Document. B. Definition of terms and concepts used repeatedly in the document. C. Description of to whom and to what the document applies. D. Most important and most frequently used general rules, followed by subordinate, specific or unusual rules and exceptions. E. Temporary provisions, if any. F. Consequences of non-compliance with applicable rules, if any. G. Administrative provisions dealing with effectiveness and responsibility for issuance, revision, maintenance, and sponsorship of the document. c. Clear and Consistent Terminology and Concepts. Clear and concise language and consistent use of terms and concepts help to avoid ambiguity and confusion when reading and interpreting the P&P Document. Particularly important is to distinguish clearly and consistently between mandatory rules and discretionary actions. d. Readability. Although consistent use of terms and good organization contribute to readability of a document, use of simple, plain language and format is important as well. The P&P Document Drafting Guide, attached as Annex 1 to this Guidance, contains recommended drafting techniques and tools to make the text clearer, simpler and more understandable to audiences within and outside the Bank, who possess varying degrees of knowledge about the institution. e. Citation to other P&P Document; Short Name. If it is necessary or appropriate to cite another P&P Document in a P&P Document, the first time a citation is made (typically in the section on definitions), the reference indicates the cited P&P Document s full title, date, and P&P Repository catalogue number. Subsequently, the short or abbreviated name of the cited P&P Document, as this has been defined, may be used to cite the P&P Document. f. Use of Annexes. Generally, relevant provisions of a P&P Document are set out in the main body of the P&P Document. In some cases, additional information may also be presented in annexes, if this is deemed important for the overall structure, completeness, and coherency of the P&P Document. An annex forms an integral part of the P&P Document, and a reference to the annex is included in the relevant section of the P&P Document. The annex to a mandatory P&P Document is also mandatory. The annex to Guidance is non-mandatory. 4. Management of a P&P Document a. Dissemination. Effective notice to staff about changes in rules and guidance may require dissemination of information in a way that staff at all levels of the Bank can absorb the change and quickly incorporate it into their work. Thus, for example, if the Sponsor is planning a Major Revision of an operational policy or a new human resources policy applicable to all staff, this would require quick and widespread dissemination to Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Page 6 of 9

8 staff at all levels. Consequently, the P&PF Procedure requires that, when applicable, the Sponsor prepare a proposed plan to disseminate the P&P Document. The Sponsor determines the manner through which the P&P Document is disseminated and communicated to the affected staff, and whether a dissemination plan needs to be prepared. The P&P Framework Administrator is available to advise the Sponsor on effective ways of developing a dissemination plan for a P&P Document, including the best way to communicate information once it has been issued. The Sponsor is therefore encouraged to consult with the P&P Framework Administrator at an early stage in the development of the P&P Document. Methods of dissemination may include publications, announcements, and training, depending on the significance of the changes implied by the issuance of such document. When the Sponsor prepares the dissemination plan, it is helpful to indicate the estimated costs of dissemination, together with the proposed timeline for dissemination. b. Interpretation. One of the functions of the Sponsor, when providing implementation support in relation to a P&P Document within its sphere of responsibility, is interpretation of the document s provisions. In some cases this involves simply confirming or explaining these provisions to staff seeking to apply it. However, in other cases it may involve a question whose answer is not self-evident from the text of the P&P Document, or a specific fact situation that is not explicitly covered by the P&P Document. In the latter cases, especially when a mandatory P&P Document is involved, the Sponsor should consider whether to consult with the lawyer most closely involved with the issue at hand (e.g., country lawyer, chief counsel, LEGOP, LEGIA) or, in cases, such as difficult Policy interpretations, the Senior VP and WBG General Counsel (in the latter case, ideally through a memorandum describing: (i) the factual background giving rise to the need for an interpretation; (ii) the P&P Document and provision in question; (iii) proposed interpretation; and (iv) rationale for the proposed interpretation). This is to ensure that the proposed interpretation does not amount to a Waiver or de-facto revision of the P&P Document, for which the P&P Framework mandates a specific process. The lawyer or VP and WBG General Counsel can advise on whether the proposed interpretation would amount to a Waiver or revision and the procedures to be followed in such case. The Sponsor may also consider whether to issue its interpretation in written form and to include it as a reference and link in the Related Document Section of the relevant P&P Document, following the processing steps for Minor Revisions. c. P&P Document Review. To ensure continued relevance of the P&P Document, the P&PF Directive includes, as one of the responsibilities of the Sponsor, monitoring and reviewing the continued relevance and applicability of the P&P Documents under its responsibility. When the Sponsor undertakes a review, it is encouraged to inform the P&P Framework Administrator on the outcome and recommendations of the review. As part of the review, the Sponsor is encouraged to examine requests for general explanations, Exceptions, Waivers, and interpretations related to provisions of any mandatory P&P Document sent to it by staff, and how they were resolved. 5. Revision to a Legacy Document Under the P&PF Procedure, a proposed revision of a Legacy Document normally requires that the Legacy Document and any associated Legacy Document be retrofitted (i.e., converted to a P&P Document format) at the time of the revision. There are two exceptions to this rule: (a) if the revision constitutes a Major Revision of a non-mandatory Legacy Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Page 7 of 9

9 Document, the non-mandatory Legacy Document need not be retrofitted if the revised document is published in the P&P Repository by July 31, 2015; and (b) if the revision qualifies as a Minor Revision, neither the Legacy Document nor its associated mandatory and non-mandatory statements (if any) need be retrofitted at the same time into a P&P Document, if the revised Legacy Document is published in the P&P Repository by July 31, P&P Framework Administrator s Role a. The Sponsor of a P&P Document is encouraged to consult with the P&P Framework Administrator and other LEG VPU staff involved in the P&P Framework as soon as it has decided to issue a new or revised P&P Document (including retrofitting of a Legacy Document as a P&P Document). The P&P Framework Administrator assists in the following areas; some of the following roles are required under the P&PF Directive; others are simply functions offered to facilitate the Sponsor s work: i. The P&P Framework Administrator advises on the proposed characterization of the P&P Document, i.e., as a Policy, Directive, Procedure, or Guidance. ii. iii. iv. Since the Sponsor is required to determine whether the proposed P&P Document may have an impact on other P&P Documents, the P&P Framework Administrator may often assist the Sponsor in assessing such possible impacts. Since any affected P&P Document needs to be revised or retired (as appropriate) in tandem with the proposed P&P Document, the P&P Framework Administrator may also assist in facilitating coordination between the Sponsors of the affected P&P Documents, and the Sponsor of the proposed P&P Document. The P&P Framework Administrator may assist the Sponsor coordinate with the appropriate LEG unit to address legal aspects of any interpretation issues, as well as any possible inconsistencies between the proposed P&P Document and other P&P Documents. If any such inconsistencies appear, it may assist the Sponsor in resolving them, and if necessary, raising the matter to higher Management levels. In addition, the P&P Framework Administrator may put the Sponsor in contact with the units responsible for IT systems, communications and training that may be required as part of the Sponsor s development and dissemination of the proposed P&P Document. b. Cataloguing and Archiving P&P Documents and Legacy Documents. The P&P Administrator is responsible for cataloguing and archiving P&P Documents as well as Legacy Documents provided to the P&P Framework Administrator for publication. This ensures systematic organization of relevant documents by topic, and storage of outdated versions. c. P&P Repository and Website. The P&P Framework Administrator is responsible for maintaining the P&P Repository and related website. d. Training; Communications; Feedback. The P&P Framework Administrator offers training and undertakes relevant communications on the P&P Framework, obtains feedback on the function of the P&P Framework, collects system diagnostics and usage data, and proposing revisions and improvements to the P&P Framework. Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Page 8 of 9

10 e. Questions on Existing P&P Documents. The P&P Framework Administrator may provide advice on general questions about the P&P Framework, and refers questions on compliance with a P&P Document to the Sponsor. f. Reports. The P&P Framework Administrator provides periodic reports to Management and other appropriate parties on the P&P Framework. g. Consultations on P&P Framework. Sponsors are encouraged to advise the P&P Framework Administrator on ways to improve the architecture of the P&P Framework and the P&P Repository to make the system more effective and useful to staff. SECTION IV EFFECTIVE DATE This Guidance is effective January 8, SECTION V ISSUER The Issuer of this Guidance is the Senior Vice President and WBG General Counsel. SECTION VI SPONSOR The Sponsor of this Guidance is the P&P Framework Administrator. SECTION VII RELATED DOCUMENTS 1. Bank Policy and Procedure Framework (R [IDA/R ]), dated July 31, 2013, approved by the Executive Directors on August 9, Bank Policy, Policy and Procedure Framework, January 8, 2014, Catalogue Number EXC4.01POL Bank Directive, Policy and Procedure Framework, January 8, 2014, Catalogue Number LEG4.01DIR Bank Procedure, Policy and Procedure Framework, January 8, 2014, Catalogue Number LEG4.01PROC P&P Document Templates and optional templates Questions regarding this Guidance should be addressed to the Sponsor. Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Page 9 of 9

11 Annex 1 P&P Document Drafting Guide 1. Sentence Structure Use short, simple sentences. A sentence that expresses a single concept is easier to understand. Several short, simple sentences are preferable to one long, involved sentence. 2. Subject of Sentence Use the person or entity to whom a role or responsibility is given, or the thing or activity that is being regulated, as the subject of each sentence. Example: A Policy is the highest level P&P Document. Do not say: The highest level P&P Document is a Policy. 3. Tense, Mood, and Voice Use the present tense and the indicative mood. Example: The Board may grant a Waiver of a Policy. Avoid use of the passive voice. Example: A Waiver of a Policy may be granted by the Board. 4. Gender Avoid using gender-based personal pronouns unless, by avoiding them, the sentence would be cumbersome. 5. Consistency Be consistent in the use of language throughout. Do not use the same word or phrase to convey different meanings. Do not use different language to convey the same meaning. Be consistent in the arrangement of comparable provisions. 6. Brevity and Simplicity Omit needless language. Aim to use language used in normal communication and correspondence. 7. Choice of Words and Phrases Use short, familiar words and phrases that best express the intended meaning according to common and approved usage. Avoid jargon, slang, overly technical language, and foreign phrases (including Latin legal terms) unless the word or phrase is a term of art. Do not use both a word and its synonym. Example: null and void, sole and exclusive. Use a pronoun only if its antecedent is unmistakable. Repeat the noun rather than use a pronoun unless the antecedent is a series of nouns. If the sentence structure is so complex Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Annex 1, Page 1 of 4

12 that a possessive pronoun seems necessary, consider redrafting the sentence rather than using a possessive pronoun. Do not use said, hereinbefore, herein, hereinafter, aforementioned, or similar words of reference or emphasis. Do not use and/or. And is conjunctive and or is disjunctive. Decide whether you mean and or or and use the proper word, recast the statement in the following manner: or, or both. Example: Board: the Executive Directors of IBRD or IDA, or both, as applicable. 8. Use of Shall, Must, and May Do not use shall or must to indicate a requirement. Instead, use the present tense and the indicative mood. Example: P&P Documents are developed, disseminated and maintained by the Bank in accordance with the provisions set out below. Not P&P Documents must [shall] be developed, disseminated and maintained by the Bank in accordance with the provisions set out below. Use may to indicate that an action is authorized under the circumstances described. Use may not to indicate that an action is not authorized under the circumstances described. Avoid using terms such as will, would, should, and ought. Terms such as will and would are predictive and are not useful in rule texts. Terms such as should and ought have a tentative meaning and are not appropriate in a rule-making context. 9. Punctuation Consider recasting a sentence if a change in punctuation might change its meaning. Use a colon to introduce a list of items. Do not use brackets as punctuation. Do not use where instead of if. 10. Definitions Define a term, whether a single word or phrase, if: a. the term has several different meanings and it is necessary to preclude any unintended construction supported by a contradictory meaning; b. the term is used in a sense that is broader or narrower than its common usage; or c. use of the defined term will avoid repetition of a lengthy phrase and improve clarity. Do not include substantive provisions in a definition. Example: in a definition of Policy, it is incorrect to add the following sentence: A Policy is approved by the Board. The sentence is a substantive provision, not definitional. Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Annex 1, Page 2 of 4

13 Arrange all defined terms in alphabetical order. Use the defined term whenever appropriate, not its definitional language. Example: use P&P Document instead of Policy, Directive, Procedure and Guidance, if appropriate. Define abbreviations and short names. Prefer short names when the abbreviation is not of common usage or inappropriate. 11. Qualifications Avoid using provided that or provided however that, or a similar proviso, where feasible. 12. Series and Tabulations Break a sentence into its parts and present them as a series in outline, or tabular, form (i.e., breaking down the elements of a sentence into readily identifiable components) only if the meaning is made clearer or if doing so makes it easier to cite to a part of the sentence. Do not include in the last item of a tabulation language meant to qualify all of the items. Example: Do not say: The development of P&P Document under the P&P Framework covers the planning and formulation of: (a) (b) (c) a new P&P Document; a revised P&P Document; or a Legacy Document being retrofitted into a P&P Document, and their issuance. The phrase and their issuance is meant to qualify all of the items and is inappropriate as part of the last item. Do not place an undesignated sentence or paragraph after a tabulation. If the sentence or paragraph is not a part of the tabulated series, draft it as a separate provision. Example: Do not say: 1. When the Board or Management issues rules or guidance regarding conduct of institutional activities, it does so in the form of a: (a) (b) (c) (d) Policy; Directive; Procedure; or Guidance. A Policy is the highest level P&P Document. The undesignated sentence A Policy is the highest level P&P Document. is more appropriate as a separate provision. Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Annex 1, Page 3 of 4

14 13. Sections and Other Designations Use the designation of sections, paragraphs, sub-paragraphs, and sub-sub-paragraphs in the provided templates whenever appropriate. 14. Arrangement of Provisions Use the arrangement of provisions in the provided templates whenever appropriate. Bank Guidance, Policy and Procedure Framework Catalogue Number LEG4.01GUID.01 Annex 1, Page 4 of 4