Policies of the Asian Development Bank are benchmarks that the Bank sets for itself to protect the rights of people affected by the Bank-funded projects and programs. All Bank policies approved by the Board should be implemented by Management and staffs, thus they should be subject to inspection.

Under the current Inspection Policy, subject to inspection has been "operational policies and procedures set forth in the Operations Manual (OM)" which serves to translate the language of the policies into a format that can be implemented by Management of the Bank.

However, the Samut Prakarn inspection revealed that several Board-approved policies were never translated into OMs, and that there were contradictions between some of the policies and their OMs. Such incomplete translation of the Board-approved policies in the OMs limited the scope of the Inspection Panel's investigation, and created controversy over the contents of the OMs.

After the conclusion of the inspection, the Board Inspection Committee (BIC) recommended ADB Management to revise the OMs to address these issues.

However, the current revision of the OM in the context of the Inspection Function review does not address these issues. Instead, Management argues its authority to decide which parts of the policies are mandatory. It proposes to exclude significant number of policies from scrutiny of the Inspection Function by changing the subject to inspection to "the policies and procedures set forth in the Compendium" which consists of very few paragraphs from 16 policies and 19% of OMs.

In conclusion, the current revision of the OM in the context of the Inspection Function review undermines the Board's authority and all of the work that has been done to improve the Inspection Mechanism in following ways:

Management lacks accountability for observing all Board-approved policies and recommendations of the Board Inspection Committee.
Management must be accountable for its commitment to implementing all Board-approved policies. However, the current Compendium allows Management to pick and choose what aspect of the policies they would like to comply with. Moreover, Management has unjustifiably opposed the recommendation of the BIC to lift the limitation on the scope of inspection resulting from lapse in incorporating policies to OM and ambiguity in OM or inconsistency with underlying policy paper.

The Compendium would severely limit the scope of the new Inspection Mechanism.
If the subject to inspection is defined as the Compendium, scrutiny by the Inspection Panel will be severely limited to only few paragraphs from a small number of policies and sections of OM. Thus, the Compendium undermines the effectiveness of the Inspection Function and accountability of the Bank to its various stakeholders, including project/program affected people, civil society organizations, and borrowing and donor member governments.

Therefore, the Compendium must be withdrawn, and all Board-approved policies and OMs should be subject to inspection. This definition should be approved at least as the transitional provision considering both OMs and policies are currently incomplete as safeguard measures. It should be the role of the Inspection body who determines what policies are applicable and thereby inspectable for each project concerned.