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
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, 2013.
2. 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 2013 1, 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.
vague ownership and unclear approval authority;
iii.
no single repository for all documents;
1
“Bank Policy and Procedure Framework” (R2013- 0156 [IDA/R2013-0214]), 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, 2012.
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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
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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.
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.
iii.
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
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of a Legacy Document, the revision triggers the need to retrofit the Legacy
Document (and associated documents)..
iii.
f.
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.
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
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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.
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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
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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
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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,
2015.
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.
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.
iii.
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.
iv.
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.
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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, 2014.
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 (R2013- 0156 [IDA/R2013-0214]), dated July 31,
2013, approved by the Executive Directors on August 9, 2013
2. Bank Policy, Policy and Procedure Framework, January 8, 2014, Catalogue Number
EXC4.01POL.01
3. Bank Directive, Policy and Procedure Framework, January 8, 2014, Catalogue Number
LEG4.01DIR.01
4. Bank Procedure, Policy and Procedure Framework, January 8, 2014, Catalogue Number
LEG4.01PROC.01
5. P&P Document Templates and optional templates
Questions regarding this Guidance should be addressed to the Sponsor.
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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
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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.
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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)
a new P&P Document;
(b)
a revised P&P Document; or
(c)
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)
Policy;
(b)
Directive;
(c)
Procedure; or
(d)
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
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