4. Ensuring efficient stakeholder engagement
All international organisations now engage with stakeholders, though to varying degrees. This chapter brings clarity into the stakeholder engagement practices available to and adopted by international organisations. IOs engage a diverse range of stakeholders, across various stages in the rulemaking cycle, and through several modalities for participation. A collection of key principles in this chapter seeks to build on these efforts by encouraging whole-of-IO approaches to stakeholder engagement, systematising mapping and selection, streamlining communications, and refining the procedures for involving stakeholders.
An overview of common challenges and recent efforts across IOs provides a state of play in stakeholder engagement at the international level. The barriers to effective international stakeholder engagement echo and amplify those at the domestic level. IOs face difficulties in managing conflicts of interest, avoiding undue influence, and reaching marginalised groups. Progress is visible in concerted efforts to establish and build stakeholder relationships, target and clarify communications, and centralise engagement responsibilities.
To be effective, international instruments must tap into a broad range of evidence and expertise. To be trusted, implemented, and complied with, international instruments need to appeal to a wider range of constituencies than the traditional membership of IOs. Reaching out beyond IO constituencies to those concerned by their normative activity is crucial to strengthen ownership of international instruments and improve implementation. Stakeholder engagement provides a practical vehicle to progress toward these objectives and enhance the quality of international instruments, and is therefore recognised as an increasing priority for international organisations. Indeed, all IOs now engage with stakeholders, though to varying degrees (OECD, 2019[1]).
In practice, however many IOs continue to face significant challenges in engaging with relevant stakeholders in a meaningful and inclusive manner, and reconciling transparency and effectiveness of discussions in the development of international instruments. Stakeholder engagement can be resource intensive, and IO staff may encounter difficulties in investing the necessary time and human capital. Stakeholder engagement of a broad audience, requires literacy and awareness of certain topics and processes among those concerned. Because of their indirect involvement with citizens, it may be particularly difficult for IOs to engage with less experienced or marginalised stakeholders. Like in domestic rulemaking, there is a risk of capture of the engagement process by those who have sufficient resources to exert influence.
This section of the Compendium aims to help IOs overcome these challenges and make stakeholder engagement an integral part of the international rulemaking process. To this end, it provides a wide-ranging account of the variety of actors involved and mechanisms used to facilitate stakeholder engagement. The common risks and challenges faced by international organisations are outlined, to assist in their effective management and enable IOs to fully unlock the benefits of engagement. While the primary inputs for this section are the practical experiences of the IO Partnership, the section is also informed by OECD work and principles on stakeholder engagement following the 2012 OECD Recommendation on Regulatory Policy and Governance [OECD/LEGAL/0390].
In the face of varying perceptions vis-à-vis globalisation and the international rules-based system, transparent, evidence-based and inclusive international rulemaking is recognised as increasingly critical. By engaging with their stakeholders, IOs can build trust in the rulemaking process and improve the quality of their instruments.
Stakeholder engagement is important from both a principled and practical perspective (OECD, 2017[2]). The principled dimension views stakeholder engagement as a core element of good governance, and a fundamental determinant of public trust, process legitimacy, and rule credibility. The practical dimension focuses on the role of stakeholder engagement in enhancing the quality of rulemaking, by allowing IOs to tap into a broader and more diverse range of inputs, broadening the evidence base underpinning international instruments, and increasing IOs’ responsiveness to the needs of those affected by their activities. Through their contributions, stakeholders can provide vital support to the implementation of an IO’s mandate and programme of work. The extent to which these benefits are realised depends on the practical management of the stakeholder engagement process by IOs.
Stakeholder engagement provides a central pillar of transparency and inclusive governance. Greater openness to stakeholder inputs can foster a sense of ownership, confidence and trust in the processes and results of rulemaking among affected parties (OECD, 2018[3]). However, the mere openness to stakeholders is insufficient to attaining these goals. A number of procedural prerequisites are important to ensure an effective dialogue. In particular, the adoption of a whole-of-organisation stakeholder engagement policy, the provision of clear and timely information regarding the opportunity to engage, the setting of appropriate expectations and procedures regarding the nature of engagement (e.g. ICN Operational Framework), and the justification of decisions to incorporate or depart from the inputs received (e.g. IOSCO Consultation Policy and Procedure) offer essential building blocks for dynamic engagement between IOs and stakeholders. The more systematic application of these procedural guarantees across IOs can build stronger incentives for stakeholders to engage more actively in international rulemaking processes and avoid consultation fatigue, knowing that their voice will be heard. Ultimately, this is key to expand the evidence base underpinning international rulemaking processes and cultivate a greater culture of transparency and inclusiveness.
Stakeholder engagement can expand the evidence base underpinning international rulemaking processes. In practice, this is facilitated through the establishment of advisory groups and expert committees, which allow IOs to tap into specialised knowledge and technical expertise. IOs also grant official status to other IOs (see Chapter 5) and non-governmental organisations, to enable them to participate in meetings and share relevant experiences. Engagement with those tasked with applying international instruments can raise awareness regarding the practical aspects of implementation, and alert IOs to challenges unforeseen during the development of rules (see Chapter 2). In some cases, the opening of stakeholder engagement processes to the wider public can help IOs to capture a diverse range of insights, some of which may be unanticipated. Beyond expanding the evidence base, engagement of various domestic stakeholders and other international organisations is likely to foster knowledge transfer, which in turn should promote greater coherence between domestic and international rulemaking processes.
This section canvasses the composition of actors involved in stakeholder engagement by IOs, as well as the various mechanisms through which this process occurs. This systematic overview draws upon the categories developed in the Brochure (OECD, 2019[1]), and provide the foundation for a strategic approach to stakeholder engagement based on the key principles outlined in the following section.
It highlights the core challenges and risks of stakeholder engagement, which must be effectively managed to ensure the realisation of its benefits. These involve, inter alia, the possibility of capture; uneven distributions of participation literacy, access, and capacity to meaningfully take part in engagement processes; the difficulty of ensuring the applicability of stakeholder contributions; applying appropriate minimum standards for the evidence submitted; and adequately identifying and managing potential conflicts of interest and other risks related to the engagement.
1. Actors: which stakeholder groups are engaged?
Results from the 2018 Survey show that the concept of “stakeholders” is broad and highly IO-specific (OECD, 2019[1]). To account for this diversity, a multi-layered classification is required (Figure 4.1), By considering the main traits of the organisations included in such a diverse classification, stakeholders may be grouped into three broad categories: i) governmental actors; ii) commercial actors; and iii) non-commercial actors, while at the same noting that such broad categories could be entangled and present hybrid elements.
Source: The Contribution of International Organisations to a Rule-Based International System, 2019.
2. Modalities: how to engage stakeholders?
Stakeholder engagement encompasses an extensive range of practices, from the dissemination of information and solicitation of consultation to participatory collaboration, coproduction, co-decision and partnership. This section highlights the various procedures and modalities used to obtain inputs from stakeholders, and identifies the stage of the international rulemaking process at which stakeholders are engaged.
Opportunity to be consulted on proposed instruments – includes a range of formal and informal modes of facilitating stakeholder contributions to specific instruments, generally proceeding according to a designated timeline, accompanied by the provision of information regarding the relevant international instrument, outlining the nature of participation, and providing feedback on the receipt/content of comments received.
Invitations to participate in instrument development – involving different types of stakeholders actively in formal or informal consultations to respect diversity of stakeholders and different points of view and directly in the design of international instruments, generally in cases where the relevant competencies are shared (see Chapter 1).
Invitations to participate in the dissemination and implementation of instruments – enlisting stakeholders in the delivery of international instruments, which may be facilitated through formal mechanisms or on an ad-hoc basis (see Chapter 2).
Invitations to participate in the monitoring of use and evaluation of instruments – engaging stakeholders in the monitoring and evaluation of international instruments, to leverage their technical expertise and/or practical experiences regarding these instruments (see Chapter 3). Encouraging dialogue between IOs and stakeholders on implementation results can help to identify structural issues in the development of international instruments that could be improved.
Official status enabling regular inputs from stakeholder groups – formalised processes of engagement with a variety of designated stakeholders, selected on the basis of particular interests, experience and/or expertise in the subject matter covered.
Invitations to participate in governing body meetings – the possibility for stakeholders to participate in work of IOs at a more strategic level through either standing or occasional invitations to the meetings of IO governing bodies.
Expert processes facilitating technical inputs from stakeholders, such as advisory groups or expert committees – involves engagement throughout both the development and delivery of international instruments with a selected group of experts, practitioners, implementers, and/or those concerned by international instruments, particularly to provide technical evidence.
Specific processes that allow engagement of wider audiences, offering in particular the opportunity for the general public to comment on proposed instruments – engaging the broadest possible range of stakeholders, generally according to a structured template for engagement.
This section highlights the key principles and steps that IOs may consider in engaging stakeholders. It builds on best practices and principles for engagement from across the IO Partnership and the OECD Best Practice Principles for Stakeholder Engagement (OECD, 2017[4]),while also bearing in mind the differences in nature, purpose and mandate between various nature of IOs and the implications that this may have for stakeholder engagement. The list of key principles suggested below is therefore not intended as an exhaustive account.
Some of these principles pertain to the need for a systemic whole-of-organisation approach; and some apply at the instrument level. At the organisational level, the adoption of a comprehensive framework for stakeholder engagement and the systematic application of a number of core stakeholder procedures would enhance the effectiveness of the international instruments and ensure the alignment between engagement processes and organisational objectives. At the level of the instrument, the adoption of consistent timing practices, facilitation of clear and detailed communication with those engaged, and systematic identification and selection of stakeholders would maximise the quality and applicability of stakeholder contributions.
1. Adopt a strategic and comprehensive stakeholder engagement approach
For successful stakeholder engagement to take place, IOs need to plan and act strategically. A clear and comprehensive approach identifying when, how and to what extent consultations with relevant stakeholders on the development of international instruments will take place is an important basis to ensure effective stakeholder engagement by IOs. A whole-of-organisation approach to stakeholder engagement will serve to enhance inclusiveness and buy-in for international instruments. The format, content and development process of this strategy will depend on each IO’s nature, mandate and governance processes.
A strategic approach offers the opportunity to set clear objectives for stakeholder engagement, and provide stakeholders with enough information to participate in a transparent, uniformly applied, and accountable process. More broadly, the objectives of the strategic approach could reflect inter alia the instrumental value of stakeholder engagement to advance the organisation’s mandate, and the support such engagement may provide to facilitate the implementation of instruments by fostering ownership across a wide range of stakeholders. These objectives may also support intrinsic values, such as ensuring accountability, and building capacity and trust in the international rules-based system. Finally, this approach may also seek to align views among stakeholders who have diverging interests and priorities, in order to build consensus on common outcomes. Any stakeholder engagement activity should be consistent with the organisation’s mandate, as defined in its constituent document(s), priorities and programme of work. This should also be respectful of the nature of the organisation concerned, including its decision-making processes and authorities.
In addition, a comprehensive approach involves the adoption of transparent processes and mechanisms to establish understanding of stakeholder engagement across the organisation and to allow for uniformity of the process and harmonisation with other practices relevant to the subject matter. These are helpful for all IO staff and members involved in the rulemaking process, and provide clear benchmarks to all parties involved regarding the added value of the consultations conducted.
At the same time, it is important that the stakeholder engagement approach and guiding principles include consultations and maintain some flexibility to be used in different circumstances. Additional tailored tools and instruments may be needed for different types of stakeholder engagement. Overall, to use resources effectively, the stakeholder engagement activities conducted by IOs need to be proportionate to the significance and impact of international instruments under discussion.
To support IO staff in the implementation of the stakeholder engagement strategy, and ensure the quality of the engagement practices and their continued relevance, the approach adopted may provide opportunities to set up a mechanism to monitor and oversee the stakeholder engagement practices of the organisation. Options in this regard may include tasking specific units and bodies within the IO itself to perform this function.
2. Ensure the effective identification and selection of stakeholders
Given the global reach of stakeholders that are potentially interested in contributing to international instruments and the broad range of public and private actors that may provide valuable insights, IOs are encouraged to identify, keep track of and reach out to relevant stakeholders depending on their nature, purpose and mandate as well as the relevant type of engagement.
An important element of reaching out to stakeholders is to identify the relevant stakeholders and keep track of their areas of work and expertise. In practice, IOs can map stakeholders according to type, mandate, function, expertise, interest and responsibilities, and keep a database of this information readily available to facilitate engagement. Such a mapping exercise will also be helpful for IOs to ensure inclusiveness and reach out to stakeholders less represented in the international rulemaking process.
Establishing clear and objective criteria informing the selection of stakeholders would further guarantee that all stakeholders are engaged in a transparent manner and without prejudice. Thes criteria may include, for example, demonstrating documented expertise in the technical area concerned and the added value that the stakeholders may bring to meaningfully support the work of the IO within its field of competence. The protection of the IO’s integrity, reputation and mandate are key considerations to be taken into account when selecting stakeholders with which to engage. This involves adequately managing potential risks, including but not limited to conflicts of interest and avoiding any undue influence in its rulemaking processes.
3. Apply robust and transparent stakeholder engagement procedures
Stakeholder engagement is a fundamental building block for the transparency and accountability of the international rulemaking process and, as such, the specifics of the engagement procedures followed require transparency, accountability and uniformity.
To ensure well-established and consistent stakeholder engagement, IOs may define the methods, tools and structure of the engagement process. These can be aligned with the general objectives, principles and standards included in the organisation-wide strategy. This will allow for those conducting the engagement to prepare and apply the processes set for the engagement, and for the interested stakeholders to understand the process they will participate in. Within this general framework, IOs may tap into a variety of practices to engage stakeholders, from the dissemination of information and solicitation of consultation to participatory collaboration, co-development of documents and partnership. These intervene at different stages of the process of international rulemaking and may be complementary. A central overview of which practices are available and applicable within the IO may guide staff decision on best practices to consider when undertaking stakeholder engagement for specific instruments.
Digital tools can be helpful for IOs to facilitate participation of stakeholders at a global level, ensuring broader participation while requiring limited resources logistically and for those participating. For instance, central consultation web-portals, referencing ongoing and upcoming engagement processes within an IO can help stakeholders to keep up with any consultations relevant to them. These portals are most helpful when made as user-friendly as possible, and enabling for example the sorting of ongoing projects according to the thematic area and setting up personalised alerts for new consultations. In addition, IOs may find it useful for the portal to enable an interactive exchange of informed-opinions among stakeholders and the IO (for instance through “discussion spaces”). Nevertheless, information and communications technologies (ICTs) should be considered in conjunction with other forms of participation to encourage more inclusive approaches for communicating with the public.
To ensure the transparency and accountability of the results of the stakeholders’ engagement, IOs may also provide feedback regarding the receipt and handling of the contributions received. This should, include the role that such contributions have played vis-à-vis the development of the concerned instrument, either individually or in a synthesised report, depending on the modalities set for the engagement. Such feedback would contribute to build public confidence in the value of the consultation process and enhance the rationale for the final adopted instrument.
4. Adopt consistent timing practices in stakeholder engagement
Along with adopting a strategic vision, identifying the appropriate stakeholders for a particular subject matter, and defining relevant tools for participation, deciding on the timing for consultations is essential in ensuring the effectiveness of stakeholder engagement. Consideration should be given to the IO rulemaking process and the flexibility for modifications, as well as the necessary time that stakeholders may need to react. IOs may choose to issue early notificiations of upcoming consultations and initiate the consultation taking into account the subsequent steps of the rulemaking process, and the additional necessary period needed to consider stakeholder inputs and advance toward the finalisation of international instruments.
5. Facilitate clear, effective and detailed communication with stakeholders
Ultimately, whatever the purpose of the engagement, whichever the modalities followed, whoever the stakeholders consulted, clear, effective and detailed communications about each individual consultation with stakeholders are key for an effective two-way process.
Clear, effective and detailed dialogue starts with informing the concerned stakeholders about the possibility and eligibility of participating in the dialogue. IOs may want to start by notifying relevant stakeholders of the opportunity to engage, through the appropriate means including the use of digital communication technologies, or whichever communications tools are used by each IO to engage with their constituency and beyond.
Clear, effective and detailed communication then entails providing relevant information about the process, the conditions for participation and the subject of engagement. As such, each consultation follows specific objectives and modalities. The units conducting the consultation are, therefore, encouraged to outline the core objectives of their stakeholder engagement process and how it aims to contribute to improving the quality and impact of the international instrument under development.
The nature of engagement should, in principle, be adapted to these objectives and fit under the broad range of stakeholder engagement practices available within the organisation. The units responsible for conducting the engagement can clarify the nature of the process and the concrete roles, responsibilities and expectations that the specific process involves for the stakeholders engaged.
To maximise the quality of the feedback received from stakeholders, consulting IO units are encouraged, to the extent possible, to provide relevant stakeholders with the most relevant and timely information available about the proposed instrument itself. In case of a proposal or draft instrument under consideration, this may include background analysis, expert papers, and descriptions of the challenges the instrument aims to address. If relevant and available, information on possible alternative solutions and approaches followed in other international, regional or national for a can also be shared. IOs may find it useful to outline specific questions for the stakeholders engaged, to guide the consultation process.
Trends in stakeholder engagement among IOs
In a context of growing uncertainty with regard to globalisation, inclusive international governance is increasingly perceived as crucial to encourage the implementation of rules and enhance trust in the international rule-based system. Stakeholder engagement is of cenral importance to promote trust and transparency in international rulemaking, following a similar trend at the domestic level in recent years (Alemanno, 2015[5]) (OECD, 2017[4]).
All IOs engage stakeholders to ensure the quality of their instruments, although to varying degrees (OECD, 2016[6]) (OECD, 2019[1]). They are increasingly opening their rulemaking processes beyond their usual constituency, by enlarging and diversifying their membership or through more systematic consultation practices with members and other non-member entities. The stronger engagement of stakeholders coincides with shifting membership structures of IOs, and a tendency to enlarge constituency beyond usual membership (OECD, 2016[6]).
Who do IOs engage with?
There is no international agreement on the concept of “stakeholders”, which is broadly-conceived and highly IO-specific. Of the IOs surveyed in 2018, only 12 reported establishing some sort of understanding of stakeholders, for the purposes of their rulemaking activities, for instance listing their characteristics or their relation and relevance to their organisation (Box 4.1) (OECD, 2019[1]).
Nevertheless, three main and non-mutually exclusive approaches to stakeholders emerge from this exercise, which reflect their relation with IOs’ normative or rulemaking activities (when appropriate) (OECD, 2019[1]):
ILAC maintains a transparent, online list of stakeholders (ILAC, 2020[7]). This encompasses representative of international, regional and national organisations having an interest in the work of ILAC including bodies such as associations of laboratories, associations of laboratory practitioners, inspection body associations, purchasing organisations, regulatory authorities, consumer associations and trade organisations are able to participate in ILAC as Stakeholder members. ILAC also has designated liaison officers with key international partner organisations, including the WTO, WHO, OECD, European Commission, APEC and the Cooperation on International Traceability in Analytical Chemistry (CITAC).
Under the Framework for Engagement with Non-State Actors (FENSA) (WHO, 2016[8]) the WHO sets out a detailed categorisation of non-state actors which includes non-governmental organisations, private sector entities, philanthropic foundations, and academic institutions. Each of these groups is subject to an explicit definition, as well as a specific policy of engagement under the overarching framework. Non-governmental organisations, for example, are described as non-profit entities which operate independently from government. Private sector entities are referred to as commercial enterprises, or businesses that are intended to make a profit for their owners, while a sub-category of ‘international business organisations’ are defined as private sector, non-profit entities that represent the interests of their membership (commercial enterprises, and/or national or other business associations. Philanthropic foundations are donor-driven entities whose income is spent on socially useful purposes, which are clearly independent from the private sector in their governance and decision-making. Finally, academic institutions are designated as entities engaged in the pursuit and dissemination of knowledge through research, education, and training.
Source: Author’s elaboration of IO practice templates and 2018 IO survey responses.
The nature and governance arrangements of IOs influence their understanding of stakeholders, and the composition of those engaged in the international rulemaking process. Private standard-setters involve business representatives and civil society more than the rest of IOs. Intergovernmental organisations (IGOs) have a more homogeneous approach to stakeholders, as going beyond government representation. In this perspective, stakeholder engagement entails engaging those that are not involved in the formal governance and decision-making processes of the IGO. In certain cases, this also means seeking expert advice on scientific and technical matters from international independent experts, so that the best available knowledge and experience can be taken into account during the decision-making process. Even this requires specific modalities and conditions as a number of IGOs seek to complement decision-making processes considered challenging to fully engage their members (OECD, 2016[6]).
De facto, a wide range of public and private actors are reported as stakeholders, ranging from government representatives, private sector actors, and NGOs among others. Representatives of other intergovernmental organisations (IGOs) represent the most significant actor engaged with by IOs in their rulemaking activities (35 respondents) (see Chapter 5), followed closely by international non-governmental organisations (33 respondents). International business associations are the private sector actors most engaged with by IOs (31 respondents). Just over half of respondents reach out to individual consumers and consumer organisations (19 respondents) (OECD, 2016[6]) (OECD, 2019[1]).
Diversifying membership of IOs and “decisional” participation of stakeholders in rulemaking
A range of new actors have emerged in global governance, producing a shift from multilateral governance to “multistakeholder governance”. Both the recent rise and loose, decentralised structure of transgovernmental networks of regulators (TGNs) serves as a testament to this trend (Abbott, Kauffmann and Lee, 2018[9]). Many IOs have enshrined stakeholder engagement in their membership by enabling “decisional” participation for the various members of society that are affected by their activities (OECD, 2016[6]) (Box 4.2).
In response to changes in global governance, IGOs have sought to expand their membership – geographically and/or in their nature – through other forms of participation, such as partial membership (which generally remains a state status); observership or stakeholder engagement. This has allowed non-state actors to contribute to the process of international rulemaking. These different forms of participation offer additional channels to engage more actively with developing countries, in line with the trends observed in the specific fields of global financial and health governance institutions (Pauwelyn et al., 2018[10]). As the world has become increasingly interconnected and economic and political centres of gravity have evolved, IOs have considered that their continued relevance and the quality of their rulemaking is a function of their capacity to involve a wider range of actors in their activities. This illustrates a broader transition beyond the strictly legal perspective regarding member or non-member rights (OECD, 2016[6]).
The membership of ASTM International (ASTM International, 2020[11]) comprises over 30 000 actors from over 150 countries, representing producers, users, consumers, governments, universities and other stakeholders. The breadth of this membership, in concert with the compact size of the ASTM Secretariat, results in a strong reliance on members to conduct a committee-led standard-development process. The primary objective underpinning this structure is to ensure an open participation in the decision-making process, promoting the representation of as many interested and affected actors as possible. This is exemplified, for instance, through the allowance of certain technical experts to participate in the standards development process with full voting rights and without charge. The organisation distinguishes between four types of membership, with different levels of access to ASTM’s standard-development activities. These include participating and organisational members, which can participate and vote in committees, and informational and student members, which constitute de facto ‘observers’ of the standards development process. Membership is open to individuals or organisations and to several individuals per country, each representing their own interests.
The Tripartite Structure (ILO, 2020[12]) of the ILO is marked by the incorporation of employer and worker representatives alongside governments. In addition to its 187 Member States, Trade Unions participate thanks to the Bureau for Workers’ Activities (ACTRAV), a specialised unit within the ILO Secretariat which co-ordinates all the Office’s activities in relation to workers and organisations, both at headquarters and in the field. Its mandate is to strengthen representative, independent and democratic trade unions in all countries, to enable them to play their role effectively in protecting workers’ rights and interests, helping them to provide effective services to their members at national and international levels, and supporting the ratification and implementation of ILO Conventions. In parallel, the ILO Bureau for Employers’ Activities (ACTEMP) is responsible for cultivating and developing the relationship between the ILO Secretariat and employers’ organisations. This is advanced through the maintenance of close and direct relations with employers' organisations across member states, to make the ILO's resources available to them, and to keep the ILO constantly aware of their views, concerns and priorities.
The IUCN applies a diversified membership model (IUCN, 2020[13]) which involves over 1 400 organisations and institutions from more than 170 countries. This encompasses states and government agencies, large and small non-governmental organisations, indigenous organisations, scientific and academic institutions, and business associations. The central objective is to mobilise the knowledge, resources, and reach of these actors in support of IUCN’s conservation efforts. A catalogue of these members is made available on the IUCN website, and is searchable by name, category, region, or state, which illustrates how the integration of emerging technologies can advance international rulemaking processes. This is supported by a dedicated Union Portal, which provides a web-based, password protected system, which allows for networking, interaction and the sharing of information across the entire Union. This represents both a working area and communication tool for IUCN constituents, as a source of knowledge, hub for the creation of new institutional partnerships, and space to explore new opportunities for engagement. The benefits of membership include influence over the trajectory of conservation and sustainable futures, participation in a collective and global voice in these areas, the development of partnerships and networks, and increased knowledge and capacity.
Source: Author’s elaboration based on IO practice templates and inputs from IOs.
Engaging with stakeholders beyond IO members: “non-decisional” participation of stakeholders in rulemaking process
A large majority of IOs have put in place mechanisms to collect inputs and feedback from stakeholders on their rulemaking and international regulatory co-operation (IRC) activities (OECD, 2016[6]). This type of stakeholder participation can be both general and specific, but remains non-decisional.
Most IOs have set up specific standing bodies or processes to engage stakeholders at key points in the development of their instruments. Stakeholder engagement practices mainly take place in substantive committees and working groups, and much less in governing bodies. In the overwhelming majority of cases (47 respondents to the 2015 IO Survey), IOs receive comments from specific stakeholder groups (OECD, 2016[6]). This trend reflects what can be observed in domestic contexts (OECD, 2015[14]). IOs frequently manage which stakeholder groups are allowed to comment, by issuing targeted invitations to particular groups (44 IOs) (OECD, 2016[6]).
To ensure that relevant stakeholders are engaged with and support the reception of effective inputs, IOs often grant certain stakeholders official status in the organisation or enable them to serve on specific advisory committees (two thirds of respondents to 2015 IO Survey) (Box 4.2). The granting of this status allows stakeholders to participate systematically in the meetings of IO bodies and obtain detailed information on the decision-making process and rules developed. As a result, the stakeholders have the opportunity to participate actively on specific issues. However, it does not grant stakeholders the right to vote in meetings, and therefore maintains a distinction with the rights of members.
The Codex Alimentarius Commission (Codex) grants nations which are not members of the FAO and WHO, but which are members of the UN, the capacity to participate in its meetings under observer status upon request. Similarly, the organisation facilitates the participation of intergovernmental and non-governmental organisations as observers through a dedicated Rule IX in the Codex Procedural Manual (Codex, 2005[15]). Taken together, this currently comprises a total of 237 Codex Observers, of which 58 are IGOs, 163 are NGOs, and 16 are UN members.
The IEC Ambassadors Programme (IEC, 2020[16]) aims to enable and enhance active involvement in IEC activities, help identify new areas of work, and underpin advocacy efforts. The selected ambassadors, as stakeholders themselves, also function as intermediaries between the IEC and key stakeholders in industry, government and academia. IEC Ambassadors are appointed by the Executive Committee for a two-year term, which can be renewed twice. They serve as independent, unpaid volunteers.
The IAF MLA Management Committee (IAF, 2020[17]) includes representatives of Users and Associations of conformity assessment bodies (CABs) as observers, in which they can provide inputs in the management of IAF peer evaluations. Moreover, the organisation operates an Associate Membership scheme in parallel to its core Accreditation Body Membership programme, which allows organisations and associations to participate in IAF decision-making and grants them diluted voting rights (i.e. the accumulated total of these votes cannot exceed 3/7 of the overall count).
In line with Article 4 of the General Regulations of the IHO (IHO, 2017[18]) and IHO Resolution 5/1957 – IHO Relations with other Organisations (IHO, 2018[19]) observers that meet the criteria listed may be invited to Assembly meetings and all subsidiary bodies of the International Hydrographic Organization (IHO) in which they have an interest and to which they are capable of making a contribution. These include governments that are not parties to the Convention, intergovernmental organisations with which an agreement or special arrangement has been made, and non-governmental international organisations with which the IHO has established relationships in accordance with the Guidelines for the Accreditation of Non-governmental International Organisations.
The WHO Regulations for Expert Advisory Panels and Committees (WHO, 2020[20]) govern the establishment of expert groups, from whom the organisations may obtain technical guidance and support within a particular subject, either by correspondence or at meetings. Membership of these panels and committees is open to any person possessing qualifications or experience relevant and useful to the organisation in the field covered. In selecting experts, the Director-General considers technical ability and experience, but also seeks to ensure the broadest possible international representation in terms of the diversity of knowledge, experiences, and approaches in the fields for which the panels have been established. For each meeting, an expert committee is required to draw up a report setting forth its findings, observations, and recommendations. To date, over 550 experts from over 100 countries have been enlisted in the support of WHO programmes.
Source: Author’s elaboration from the 2018 IO Survey.
Overall, external stakeholders are mainly engaged in the technical, upstream phases of the work. They are often sought to make contributions on data collection, to offer advice or technical expertise, to participate in research activities and policy analysis, and to support the adoption of international instruments. In addition, stakeholders are often invited to provide financial or in-kind contributions to IOs’ activities (OECD, 2016[6]) (OECD, 2019[1]). The specific mechanisms used to engage stakeholders and the intensity at which engagement is pursued vary according to the type of actvity undertaken by Ios (OECD, 2016[6]).
Challenges to international stakeholder engagement
Despite increasing efforts to provide stakeholders an opportunity to participate, IOs still face constraints in setting up reforms for “good participation” that entail removal of barriers to involvement and managing risks such as conflict of interest and undue influence.
Challenges of stakeholder engagement around national rulemaking may be amplified at international level. At the domestic level, stakeholder engagement is perceived as resource intensive, requiring significant time and human capital (Alemanno, 2015[5]). In the absence of a specific mandate to conduct stakeholder engagement, IO secretariats may face difficulties investing sufficient resources in consultation. In this sense, IOs may be still more limited in their ability to reach less-experienced or marginalised stakeholders, although it remains to be seen whether IOs with a strong presence at country level face the same challenges.
The 2018 IO Survey illustrates that the major challenges IOs perceive in engaging stakeholders involve managing existing or potential conflicts of interest, avoiding undue or improper influence on the organisation’s work, reaching out to unaware or under-represented stakeholders, and engaging effectively with marginalised stakeholders (OECD, 2019[1]).
Despite the undeniable efforts of a large majority of IOs to engage more systematically with stakeholders, their practices in terms of mechanisms, openness and frequency of consultation vary widely from one organisation to another and occasionally across departments, programmes and bodies within individual IOs. This makes it difficult to provide a global view. Many efforts can be identified across IOs to lay down stakeholder engagement practices, but these are most often focused on specific stakeholder groups, most often from the private sector, or relate to selected parts of their respective work-streams (Box 4.4).
The adoption of a clear, whole-of-organisation stakeholder engagement policy remains the exception among IOs. Except for a couple of IOs responding to the 2018 IO Survey, there is no set of minimum standards that determine a consistent vision of the purpose, ways and timing of stakeholder engagement (OECD, 2019[1]). As a consequence, stakeholder engagement is rarely undertaken strategically and systematically with clear timelines, phases, mechanisms, and systematic feedback.
The Codex Principles Concerning the Participation of International Non-governmental Organizations in the Work of the Codex Alimentarius Commission (Codex, 2005[15]) govern the granting of observer status to international non-governmental organisations, which allows those holding such status to participate in meetings, without the right to vote, submit written statements, and receive all working documentation and discussion papers. These organisations must also fulfil a range of obligations, including a commitment to advancing the objectives of the Joint FAO/WHO Food Standards Programme, co-operate with the Codex Secretariat to avoid duplication and overlapping activities, promote better knowledge and understanding of Codex, share reports and publications to the Secretary of the Commission, and report promptly any changes in its structure and membership. From the perspective of Codex, this collaboration supports the acquisition of expert information, advice and assistance from international non-governmental organisations, the reception of the views of their members, and the harmonisation of inter-sectoral interests.
In line with its Approach to Advancing Accountancy Education, IFAC is currently developing a Multi-Stakeholder Engagement Framework (IFAC, 2019[21]). The relevant actors envisaged for inclusion within the framework include adopting authorities, those involved in the initial preparation and continuous development of professional accountants, and those who use the services of professional accountants. The nature of stakeholder engagement foreseen is composed of three key pillars. First, an online survey will be used to identify developments, propose potential improvements to the education programme, and establish relevant topics to be addressed. Second, an International Forum for Key Accountancy Education Stakeholders will be held every two years, comprising representatives from interested organisations and tied into the implementation of survey outcomes. Third, an International Forum for Accountancy Education Directors will provide advice on the continued appropriateness of the programme and needed revisions, inform implementation support, and identify opportunities for collaboration and knowledge-sharing.
The IUCN Operational Guidelines for Private Sector Engagement (IUCN, 2009[22]) cover all aspects of developing, implementing, managing and concluding an engagement with the private sector. This outlines processes for defining the nature of engagement, selecting partners, negotiating and formalising engagement, and implementing, managing the engagement, and concluding the engagement. The Guidelines emerged from the third IUCN World Conservation Congress, held in Bangkok in 2004, and are grounded in twelve Principles of Engagement. Engagement between IUCN and the private sector must be relevant to the IUCN vision and mission, consistent with the general policies of the organisation, responsive to the aspirations of its membership, empower the IUCN to implement its programme, generate concrete results, promote the efficient use of resources, transparent in ensuring access to necessary information, participatory in creating opportunities for involvement by affected stakeholders (with a particular emphasis on vulnerable groups), enhance the credibility and autonomy of the IUCN, promote further development and inclusion of the principle of Free Prior and Informed Consent, build on commitments to supporting sustainable development, and ensure the independence of IUCN from the company or industry group with which co-operation takes place. Each engagement initiative is informed by a dedicated ethics framework, and subject to evaluation and feedback under the IUCN Monitoring and Evaluation Policy.
Introduced in 2013, the PIC/S Guidelines on Professional Organisations describe how to co-operate with these organisations – notably when organising joint training events (for regulators and industry). The core objective of the Guidelines is to facilitate co-operation with other organisations in the field of pharmaceutical manufacturing, which are important to PIC/S and which can significantly contribute to PIC/S’ goals. The core results of this initiative consist in avoiding the duplication of activities within the same field, facilitating synergies across stakeholders, pooling resources, and increasing PIC/S’ visibility and reach. The delivery of joint events is evaluated internally by the PIC/S Subcommittee on Training.
The WCO Private Sector Consultative Group (PSCG) (WCO, 2005[23]) is a WCO body, consisting of 27 private sector representatives from associations covering different industry sectors, different sized businesses and all six WCO regions. Under normal circumstances, it meets twice to three times a year at the WCO Headquarters. Furthermore, its members take an active part as observers to WCO working bodies and contribute to the development of its instruments and tools. The PSCG’s key deliverables involve informing and advising the WCO Secretary General, the Policy Commission and WCO Members on Customs and international trade matters from the perspective of the private sector; supporting the adoption and effective implementation of agreed WCO and other relevant international instruments; and leveraging business resources and government relationships to advocate for and implement programmes developed and adopted by the WCO. The PSCG was established with the approval of the WCO Council, and its activities are framed by a dedicated Terms of Reference. During the first four months or more of the COVID-19 pandemic, the PSCG was holding virtual weekly/bi-weekly online meetings with the WCO Secretary General, Deputy Secretary General and Council Chairperson, to provide status updates relevant to their respective industries, discuss the impact of the COVID-19 pandemic on international trade and the global economy, and explore proposals for courses of action by the global Customs community.
Source: Author’s elaboration based on IO Practice Templates.
IO efforts to overcome challenges to effective stakeholder engagement
IOs are pursuing a variety of initiatives to ensure that their engagement with stakeholders is effective and offers meaningful inputs to their rulemaking activities. For instance, a majority of IOs responding to the 2018 Survey provide a minimum period for feedback. In addition, specific efforts are being undertaken to reach out to more interest groups and to ensure that stakeholders are also consulted without prejudice to their status or resources. To this end, a large share of IOs make available relevant and timely information about the subject of consultations, proactively build a relationship with stakeholders over time, or provide information in a clear language, easy to understand (OECD, 2019[1]).
Despite its recognised importance, few IOs have developed a whole of organisation policy or strategy for stakeholder engagement to date, mapping their stakeholders and defining objectives and key steps to engage them and manage risks. They mostly rely on provisions in founding or procedural documents highlighting its importance, rather than a framework of systematic practices and tools. There are exceptions to this broad feature. Certain IOs, such as the WHO, have a more systematic approach to stakeholder engagement (OECD, 2016[24]). Without going that far, many IOs have taken pragmatic steps to structure their engagement with other IOs and establish principles applying to observers or specific groups, such as those in the private sector (Box 4.5) (see Chapter 5).
Beyond a comprehensive policy, some IOs have developed concrete guidance to support IO secretariat staff and rulemaking bodies in engaging effectively with stakeholders.
Policies and guidance documents are in certain cases complemented – or substituted – by a dedicated body in charge of overseeing stakeholder engagement throughout the Organisation (Box 4.6). Six respondents to the 2018 IO Survey indicate having some sort of oversight mechanism of their Organisation’s stakeholder engagement activities. Beyond formal oversight, 19 indicate having some informal co-ordination mechanism or practice group in place that brings together staff members working on stakeholder engagement (OECD, 2019[1]).
Some organisations request partner entities and stakeholders to appoint liaison officers to have single contact points for engaging in their organisations’ work, to channel the inputs received and potentially help reduce the resource needed to process comments and contributions (Box 4.7).
The risk remains that progress in engaging stakeholders stays limited until further understanding on the impacts of stakeholder engagement practices is gathered. Only a few IOs evaluate their stakeholder engagement efforts as is recommended at the national level, with only eight IOs responding to the IO 2018 Survey having in place a formal mechanism to track and measure the impact of stakeholder engagement on the organisation’s work (Box 4.8).
More broadly, the allocation of roles and responsibilities between IOs and their respective members is of central importance, and building greater connection between the two levels is an area to be further explored. Members are closer to the field where international rules apply, and consequently closer to the evidence and lessons learned needed for good rulemaking as well as the stakeholders affected by these rules. They have a critical role to play in sharing information and identifying relevant stakeholders. Through their own open-government and stakeholder engagement practices, they also have processes in place to inform and engage stakeholders in rulemaking that could form a relevant channel for international norms. However, stakeholder engagement in international rulemaking is largely disconnected from their engagement at the domestic level so far (OECD, 2018[3]).
The IOSCO Consultation Policy and Procedure (IOSCO, 2005[25]) was adopted in 2005. This stipulates that the organisation must establish the rationale for seeking stakeholder inputs in its consultation reports; offer a period of three months for the reception of these inputs; publish contributions within a dedicated online ‘Public Documents’ interface; and provide an explanation for the manner in which comments have been addressed. The primary objectives which IOSCO seeks to advance through its consultation activities include obtaining substantive inputs to the organisation’s work; benefitting from the expertise of the international financial community in assessing and analysing regulatory issues; obtaining information and views on the potential impacts, benefits and costs of any proposed standards and principles; promoting understanding of IOSCO’s mission as the “international standard setter” for securities markets; increasing the transparency of the organisation’s activities and work programme; to foster and enhance consistency through early dialogue with the private sector and forging approaches to deal with common concerns; and contributing to the convergence of securities regulatory standards. There is also a list of factors framing the decision to seek public comments, as well as the form of each consultation process.
The engagement activities that occur between the OIML and its stakeholders are framed by a Policy on Liaisons between the OIML and other Bodies (OIML, 2004[26]) which was adopted in 2004 and is published on the organisation’s website. The policy distinguishes between six categories of actors, including intergovernmental bodies and development organisations; regional metrology organisations and regional legal metrology organisations; international standard-setting organisations and international accreditation organisations; regional and national standard-setters; and industrial federations and other bodies. In relation to each of these organisations, the OIML outlines the various modalities through which stakeholder engagement is pursued. For example, intergovernmental bodies and development organisations receive the OIML Bulletin and all relevant information regarding its rulemaking activities; are invited to report annually to the OIML about their metrology activities; are able to attend the Conference and CIML Meetings in the capacity of observers; and may establish co-operative agreements as well as joint working groups to develop technical documentation or carry out studies, advocacy initiatives, or capacity-building initiatives in developing countries.
Introduced in 2016, the WHO Framework for Engagement with Non-State Actors (FENSA) (WHO, 2016[8]) establishes an overarching stakeholder engagement approach which is applicable across all levels of the organisation. FENSA endeavours to strengthen engagement with non-State actors (NGOs, private sector entities, philanthropic foundations, and academic institutions) while protecting its health-related work from potential risks such as conflicts of interest, reputational risks, and undue influence. Across each of the four categories of non-state actors, the organisation has developed a tailored policy and a differentiated set of operational procedures. The Framework also sets out a range of stakeholder engagement modalities, including participation in consultations, hearings, and other meetings of the WHO’s provision of financial or in-kind contributions; submissions of evidence; co-operation in advocacy activities; and technical collaboration in product development, capacity-building, emergency responses, and contributions to the implementation of WHO policies. FENSA also establishes detailed mechanisms to manage and mediate conflicts of interest, as well as other risks of engagement.
Source: Author’s elaboration based on IO practice templates and inputs received from IOs; (OECD, 2019[1]).
The BIPM operates a dedicated International Liaison and Communication Department (BIPM, 2021[27]), which oversees its stakeholder engagement and international co-ordination activities. In particular, this department manages liaison with other intergovernmental and international bodies, supports the promotion of the Metre Convention and the International System of Units (SI), and underpins the CIPM Mutual Recognition Arrangement – the core instrument of the organisation.
The Global Stakeholder Engagement (GSE) (ICANN, 2020[28]) team in ICANN is responsible for leading engagement and outreach to stakeholders on ICANN and its mission around the world. The team provides a point of contact in the regions for the ICANN Organisation and the ICANN Community, raising awareness, providing outreach and understanding of ICANN's role and remit, driving participation in ICANN policy development and technical activities. The team is at the forefront to deliver on ICANN's Commitments and Core Values to ensure broad, informed participation reflecting the functional, geographic and cultural diversity of the Internet. The GSE team comprises 34 staff across 21 countries, and provides for the management and oversight of ICANN’s engagement function in eight regions of the world.
The ICN has a designated Non-Governmental Advisors (NGAs) Liaison (ICN, 2020[29]), whose mandate is to better engage NGAs to participate in the ICN. More broadly, the central objective of this practice is to expand the spectrum of experiences, expertise and interests informing the development of ICN products.
ILAC has dedicated liaison officers, which establish, build, and manage relationships with all key international partner organisations.
Each liaison organisation that the OIML works with appoints a liaison officer. These include international business organisations, intergovernmental organisations, and others IOs. The liaison officer acts as their organisation’s representative (without committing their organisation) with the OIML.
Source: 2018 IO Survey, and Author’s elaboration based on inputs received from IOs.
The ICN has developed a Non-Governmental Advisors (NGAs) Toolkit (ICN, 2020[29]), which aims to support engagement both from the perspective of member agencies and existing and prospective NGAs. These actors include competition experts in the form of lawyers and economists from private practice, in-house counsels, representatives of non-governmental IOs, members of industry and consumer groups, academics and judges. The document also sets out the various channels through which NGAs can participate in the ICN’s working groups, including through their consultation in the creation of work plans, commenting on or contributing to written work, and engaging in meetings and events (conference calls, webinars, workshops, and the ICN Annual Conference). The toolkit outlines how NGAs can benefit the ICN, through inclusiveness, dissemination of communications and work, and resource-sharing; as well as how the ICN can help NGAs in network-building, the ability to contribute to the formation of international competition policy, and knowledge-promotion.
The WHO has produced a Handbook for Non-State Actors for Engagement with the World Health Organization (WHO, 2018[30]). First, this begins by providing a basic description of the Framework for Engagement with Non-State Actors (FENSA), the organisation’s overarching strategy for stakeholder engagement, as well as setting out a definition of a ‘non-state actor’. Second, the document subsequently establishes the various groups of non-state actors, and the mechanics underpinning the decision to categorise these actors. Third, the Handbook outlines the various types of engagement that take place through FENSA, including technical and scientific inputs to transmit information and knowledge, advocacy and awareness-raising activities with regard to health issues, and technical collaboration on product development, capacity-building collaboration in emergencies, and contributions to the implementation of WHO policies. Fourth, the overarching principles applying to engagement are enumerated, including that any stakeholder engagement initiative pursued must demonstrate a clear benefit to public health; conform to the WHO’s Constitution, mandate, and Programme of Work; respect the intergovernmental nature of the WHO and the decision-making authority of Member States; support and enhance, without compromising, the scientific and evidence-based approach that underpins the WHO’s work; protect the WHO from any undue influence; not compromise the WHO’s integrity, independency, credibility and reputation; be effectively managed to avoid conflicts of interest and other risks; and be conducted on the basis of transparency, openness, inclusiveness, accountability, integrity, and mutual respect.
The IOSCO Consultation Policy and Procedure, IUCN Operational Guidelines for Private Sector Engagement, OIML Policy on Liaisons, WCO Terms of Reference on the PSCG, Codex Principles on the Participation of NGOs, and PIC/S Guidelines on Professional Organisations, as well as WHO’s FENSA itself, described in previous boxes, also display at least some features and aspects of guidance on stakeholder engagement.
Source: Author’s elaboration based on IO practice templates, 2018 IO survey.
According to their terms of reference, the Assessment Body Advisory Committee (CABAC) and User Advisory Committee (UAC) of the IAF monitor the responses to their recommendations. More broadly, the IAF Board reviews the performance of all Main and Advisory Committees on an annual basis.
ILAC has built-in review clauses embedded within its Supplement to the ILAC Strategic Plan 2015-20. Under Action 2.4 of this document, the organisation is currently reviewing key relationships to leverage limited resources and adjust priorities in response to emerging circumstances. This will form the basis for a dedicated strategy for stakeholder engagement, which will presumably be introduced within the scope of the next strategic plan.
The ILO provides a comprehensive Development Cooperation Dashboard, which tracks the full range of the organisations’ initiatives in this area as well as the stakeholder funding and collaboration on these projects. This comprises its rulemaking activities, including enhancing labour standards, advancing social protections, and – with particular reference to its stakeholder engagement activities – strengthening tripartite constituents with a view to facilitating influential and inclusive social dialogue.
Pursuant to Article 3(6) of the Framework for Engagement with Non-State Actors (WHO, 2016[8]), the WHO is currently conducting an initial evaluation of its implementation and its impact on the work of the organisation. The results of this evaluation, together with any proposals for revisions of the framework, will be submitted to the Executive Board through its Programme, Budget and Administration Committee. This provides a practical illustration of how the results of evaluation processes can underpin and contribute to programme improvements.
Source: 2018 IO Survey, Author’s elaboration based on inputs by IOs.
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