ILA Report 2004, p. 6.

 ILA Report 2004, p. 5.

 Anthony et al. (2011), supra note 28, pp. 1–16; Kingsbury et al. (2005), supra note 29, p. 139.

 Klabbers (2009), supra note 25, pp. 4–5.

 Chesterman (2008), supra note 45, p. 35.

 Freestone (2003), supra note 19, p. 144.

 Shihata (2000), supra note 5, p. 13.

 Freestone (2003), supra note 19, p. 143.

 Definitions Page, supra note 75.

 Freestone (2003), supra note 19, p. 143.

 As at June 2012, there were only nine Op Memos and one GP.

 Freestone (2003), supra note 19, p. 143.

 IFC, CAO Annual Report 2011, p. 9, available at: <www.cao-ombudsman.org/publications/>.

 IFC, CAO Annual Report 2011, p. 9, available at: <www.cao-ombudsman.org/publications/>.)| false
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 Freestone (2003), supra note 19, p. 142.

 Freestone (2003), supra note 19, p. 142, quoting Shihata (2000), supra note 5, p. 42.

 Shihata (2000), supra note 5, p. 41.

 Hunter (2010), supra note 5, p. 199. And see Shihata (2000), supra note 5, pp. 155–203. For an account of NGO participation in the 1999 Board review of the Inspection Panel Resolution, see D. Bradlow, ‘Precedent-Setting NGO Campaign Saves the World Bank’s Inspection Panel’ (1999) 6 Human Rights Brief p.7.

 Effective since 1 July 2010. The new policy makes a significant portion of documents available (e.g., minutes of Board meetings), and works on the principle “that the World Bank will disclose any information in its possession that is not on a list of exceptions” (compared to working with a list of documents that are available to the public). Another change of note is the possibility of appeal, should an individual be refused access to a particular document. See World Bank Group, ‘New World Bank Access to Information Policy Takes Effect July 1’, (3 June 2010) Press Release No. 2010/448/EXC, available at : <http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/EXTPOLICIES/EXTOPMANUAL/0,,contentMDK:22105228~menuPK:51455649~pagePK:64141683~piPK:64141620~theSitePK:502184,00.html>.

 As at July 2012, only 29 (out of 86) CAO cases went to the (initial) compliance review stage; moreover, in several of these compliance review cases, there is (currently) no documentation available (typically because of current confidentiality issues, or because the case did not actually proceed to the full compliance audit stage): See e.g., Indonesia Wilmar Group-02/Sumatra (Complaint filed 1 December 2008); Georgia / BTC Pipeline-26/Krstanisi (Complaint filed 12 December 2005); and Georgia / BTC Pipeline-27/Tbilisi (Complaint filed 15 June 2005). Also see supra note 97.

 Shihata (2000), supra note 5, 41–49. See also, e.g., DRC Anvil Mining Congo SARL 01 WB President Request (Complaint filed 1 July 2005), Compliance Advisor Ombudsman, Audit Report (November 2005), para. 3.3.4: “The CAO does not claim that if Anvil had fully implemented the Voluntary Principles, the events at Kilwa would have taken a different course. This remains an area of uncertainty, and in volatile operating environments there is a residual risk that abuses may happen even where the Voluntary Principles have been followed. Had the Voluntary Principles been applied in a systematic manner, however, they would have provided an essential bridge across the current disconnect between the treatment of conflict as an insurable risk, and the potential for a project to influence the dynamics of conflict in a way that might cause harm to local communities. For MIGA’s due diligence to have been adequate, it would have needed to systematically review its clients’ work on implementing the Voluntary Principles and satisfy itself of the adequacy.”

 Bottelier (2001), supra note 20, p. 11.

 CAO Operational Guidelines, supra note 100, para. 3.3.3 (emphases added).

 Shihata (2000), supra note 5, pp. 41–49.

 CAO Operating Guidelines, p. 18.

 CAO Operating Guidelines, p. 18.

 CAO Operating Guidelines, p. 19.

 CAO Operating Guidelines, p. 26.

 CAO Operating Guidelines, p. 33.

 Chesterman (2008), supra note 45, p. 15.

 As at 1 July 2002, available at <http://go.worldbank.org/WTA1ODE7T0>. Note: at the time of writing, a review of the World Bank Safeguard Policies was underway.

 As at 1 July 2002, available at <www.ifc.org/sustainabilityframework>.