JULy 2008 45038 aboUt the aUthor Support emergence of home-Grown martIn norman recently joined IFC bICF as Policies by Putting Local Partners in Program manager, economic Zones. he began his career in the Drafting Seat Latin america, where he spent 10 years managing and marketing free trade zones. he was the General manager In September 2007, the Government of ban- ing a"home-grown"policy on economic zones--one of el Progreso, the first private gladesh (Gob) requested that the board of In- developed by bangladeshis for bangladesh's eco- free zone in el Salvador, and subsequently became the first vestment draft an economic zones policy (eZ nomic zones. the idea was that IFC bICF would hire a General manager of american Policy). the policy was to cover the entire zone local consulting company with expertise in drafting Park, a greenfield operation regime of bangladesh, including export pro- legislation and with some technical experience in that had become one of the cessing zones, industrial estates, and special economic zones, provide the local company with ex- three largest free zones in el economic zones, both public and private. ex- tensive orientation on international best practices, Salvador by the time he left in 2003. port processing zones had long been a key and orchestrate a rigorous review process by stake- tool in bangladesh for creating jobs and in- holders at all levels. creasing exports. In addition, there were 67 industrial estates ­ at least one in each of ban- once the local company had completed the gladesh's 64 districts ­, which catered primarily draft policy, IFC bICF used both large consulta- to the domestic market. both the eight export tive group sessions and smaller focus groups to processing zones and the industrial estates get the input of stakeholders and incorporate had had mixed success. the most relevant comments into the final pol- icy statement. Finally, after the draft policy arrangements for combining best inter- had been submitted to the Gob, IFC bICF ar- national practices with local knowledge: ranged for key experts, both local and interna- a home-grown hybrid approach to poli- tional, to intervene directly with the Chief ad- cy development visor's (equivalent to the Prime minister's) office during the final Gob review process. When the Gob commissioned the eZ Policy, the this ensured that best practices continued to IFC bangladesh Investment Climate Fund (bICF) be communicated to the decision-makers even agreed to fund the drafting of the policy. In after the formal consultative process had fin- doing this, IFC bICF could have contracted an ished. international consulting company with world- wide expertise in drafting eZ Policies in multi- the entire process took approximately eight ple countries to draft the ideal policy that months: three for drafting the policy, three for would have incorporated the best internation- the consultative process, and two for the final al practices available, avoided common pitfalls review by the Chief advisor's office. in developing economic zones, and relied on the traditional wisdom of the best practitio- Lessons Learned ners. this approach would have amounted to IFC bICF saying to the Gob, "here's the policy. our approach and the steps taken proved to be ex- It's based on international best practices ­ now im- tremely effective, but in retrospect the following les- plement it!" sons on what to do and what not to do were learned from both our advisory work helping the local con- In discussing this approach, IFC bICF felt strongly that sulting company draft the policy and our input into in bangladesh, as in many other countries, the reac- the consultative process. tionoflocalstakeholderstoreceivingapolicydrafted by a third-party consultant or donor organization for 1) the local consulting company needs to be in implementation would be one of resistance. buy-in the drafter's seat both in truth and perception. to a policy developed externally would be minimal, and implementation would be spotty at best. IFC bICF felt it important not to "strong-arm" the drafters into accepting IFC bICF's position on the We decided to take a different approach by sponsor- policy; rather, IFC bICF worked behind closed doors IFC SmartLeSSonS -- JULy 2008 1 the consultants and the government, which also compiled and distributed stakeholder comments. oUr aDvICe: resist the temptation to intervene! you should be in attendance for all the sessions in order to gauge the general feeling about the policy and understand which aspects of the policy are of most concern. however, for a home-grown policy it is extremely important that your interventions and those of any international experts be minimal. Staying quiet when opinions expressed are far from correct requires a degree of self-restraint, but dem- onstrating your expert knowledge will "blow your cover," and the more you speak, the more the policy will be identi- fied by the country as "the World bank Policy" rather than "our policy.". 2) the earlier stakeholders receive the policy for review Large consultative group sessions on eZ policies before the consultative sessions, the better. In coordination with the local consulting company, the Gob convened the stakeholder consultation meetings, sent out the invitations, and distributed the policy. on several occasions, meetings were convened on very short notice (less than 48 hours in advance), and the policy was some- times distributed less than a week before the consultative session. as a result, key stakeholders often arrived at the sessions unprepared (i.e., not having read the policy). oUr aDvICe: the sooner the invitations and the draft policy can be sent out to stakeholders before the sessions ­ ideally at least a week beforehand ­ the better. 3) Large consultative sessions should seek to explain concepts, leverage the knowledge of the participants, and allow sufficient time for Q&a. Smaller focus groups to consult stakeholders input a total of five large stakeholder groups of 30-40 stakehold- ers each were assembled to obtain the collective opinion on the policy from all government organizations involved in to ensure that each point of the policy received lengthy discussion, the economic zone regime as well as from private sector hashing through ideas and brainstorming with the drafters. hours chambers of commerce and industry associations, individual were also spent to ensure that the drafters had a thorough under- large companies, and civil society and donor groups. standing of international best practices, such as complying with Wto agreements and internationally accepted social Large consultative sessions require careful planning. often and environmental standards, and working toward a multi- we found that comments were solicited from stakeholders modal hybrid model for economic zone development. In in the consultative sessions before they understood all the addition, the following helped preserve both the percep- concepts. the organizers of the sessions tried to get through tion and the reality of a home-grown policy: all the points of the policy (more than 60) in too little time, and the · the eZ policy was always referred as the"home- sessions were too formal to foster dynamic discussion. Ideally, ses- grown policy,"as opposed to the"World bank Policy"or"IFC sions should last about three hours and should be broken down Policy." this messaging was managed by IFC bICF in such a more or less as follows: way that the Gob, the local company, and all World bank · explanation of concepts. the basic concepts should be pre- Group entities working in the country referred to it in this sented in an initial session of from 15 to 30 minutes, depend- way; ing on the complexity and nature of the policy area and the · IFCbICFmaintainedalowprofile. allmediaandotherinquiries capacity of that particular group of stakeholders. In our case, on specific points of the policy were directed to the local con- as we noted with successive consultative sessions that par- sulting company drafting the policy; and ticipants lacked a basic understanding of the concepts, the · IFC bICF found creative ways of remaining pro-active while local drafters of the policy began to dedicate the beginning playing a behind-the-scenes role. While IFC bICF actively of each session to a half-hour explanation of what an eco- identified key stakeholder groups for consultation, it left the nomic zone is and its importance to the economy; official invitations up to the local company and the govern- · review of policy statements. organizers of the consultative ment. It shared ideas with the local company as to how to sessions should go over the basic provisions of the policy for organize consultative sessions, but all sessions were led by about 30 minutes, and should focus on those articles of most IFC SmartLeSSonS -- JULy 2008 2 interest for a particular stakeholder group. much less effective · encourage private sector stakeholders to overcome inourcaseprovedtobetakingfourorfivepolicystatementsat defeatist attitudes toward advocacy. as private sector a time for comment, and thus working through the 60+ policy representatives became passionate about aspects of statements in about two hours. rather, we found that the policy, IFC bICF was able to give them a vision for only about 20 percent of the policy statements consti- what advocacy efforts can achieve when the private tuted 80 percent of the concerns of each individual sector speaks with one voice. then, we targeted the stakeholder group. Focusing on the most important most passionate and influential of the stakeholders policy statements makes for a more dynamic discussion for additional one-on-one meetings for the purpose and allows stakeholders to concentrate only on those of converting them into long-term champions; and policy statements of greatest concern ; · encourage these key stakeholders to put their com- · Presentation and delivery of written comments. ments in writing. this will increase the likelihood that Some of the stakeholders will have prepared written their comments will be read and considered for the final comments before the consultative session. approxi- policy. mately 30 minutes should be set aside for the repre- sentatives of these institutions to present their writ- oUr aDvICe: Invite key stakeholders to attend small fo- ten comments. a deadline for all additional written cus groups before the large consultative sessions, and tar- comments prepared after the consultative session get them for subsequent one-on-one discussions designed should be clearly announced during each session; to make them long-term champions. and · open Discussion. by far the lion's share--approximate- 5) Providing constant feedback to all stakeholders is of ly an hour or more as time permits--of the session vital importance. should be dedicated to open discussion. this is what will get participants excited about the content of the During the consultative process, the local consulting com- policy, and passionate about the articles of the policy pany that had drafted the policy was in charge of gather- about which they have major concerns. ing and compiling all comments and recommendations obtained during the consultative sessions by the various oUr aDvICe: Plan the large consultative sessions carefully, stakeholder groups. these comments were presented in a make sure at least the basic concepts are understood, but matrix by stakeholder group, assembled in a single spiral- keep presentations short and discussions long. bound publication, and distributed to all representatives on all the stakeholder lists. this was done in a timely fash- 4) Small focus groups of key stakeholders before the ion (within two weeks after the consultative session itself) larger stakeholder sessions are the key to the success of and was instrumental in enriching the dialog during the the consultative process. sessions. each of the large consultative sessions was preceded by oUr aDvICe: Compiling stakeholder comments and rec- a small focus group of six to eight of the most influential ommendations is tedious work, but don't let it fall behind! opinion leaders within each large group. as the stakeholders see that their comments have not only been heard but documented in writing, they will feel these smaller focus groups were the key to the success of that their voice has been heard. this is crucial for buy-in, the consultative process. they generally took place a especially from those who will subsequently be imple- day or two before the large consultative sessions, and menting the policy. allowed IFC bICF the opportunity to provide more direct inputs to participants in these groups and to take more 6) be proactive with media relations. of an active role in shaping opinion and imparting inter- national best practices. Specifically, small focus groups Consider the role of the press. In this case, the government de- provided IFC bICF with an opportunity to do the following: cided that it was not desirable to have the press involved in every · encourage the key opinion leaders to read the policy. We twist and turn of the process. this is understandable, but IFC bICF were quite concerned to find out at the large consultative feltthatthemediawouldbecuriousabouttheprocessandwould meetings that so few of the key opinion leaders had even seek information where they could find it, even from individuals read the policy. meeting with them in a small group or indi- who were not wholly familiar with the policy. In keeping with the vidually a few days before the large consultative session, and behind-the-scenes approach, the strategy we decided to pursue encouraging them to read the policy before the large ses- was to communicate targeted messages to key journalists on the sion, was key to a vibrant, participative consultative session; policy and to explain the policy draft-consultation-approval pro- · Pointoutkeyclausesandaskleadingquestionstostirupapas- cess informally. our existing relationships with the media allowed sionate response to the policy. much more effective than us to include these messages as part of our ongoing communica- "preaching" about best practices and talking about our opin- tions with them, and the informal nature of our contact presented ion was pointing out hot-button items that would be impor- no challenges to official government media relations. tanttothosestakeholders. thispartwaseasy. allwehadtodo to get key opinion leaders passionate about the policy was to In this way, as the media received reports on the policy from the observe, "Do you realize that the policy will triple the work of various sources that were involved, they were already familiar everyone in your department?"or"I hope you realize that the with the concepts and were able to filter the information they price paid in private economic zones will be controlled by the were receiving from a more informed standpoint. government."; IFC SmartLeSSonS -- JULy 2008 3 oUr aDvICe: make sure your existing rela- tionships with the media are good, and be pro-active behind the scenes to control the messages about the policy. Conclusion If the above-mentioned guidelines are fol- lowed, the country will end up with a good policy that has a greater likelihood for imple- mentation. and at the end of the day, a good home-grown policy that is implemented prop- erly is better than the "perfect policy" that sits on a shelf. DISCLaImer IFC SmartLessons is an awards program to share lessons learned in development-oriented advisory services and investment operations.the findings, interpretations, and conclusions expressed in this paper are those of the author(s) and do not necessarily reflect the views of IFC or its partner organizations, the executive Directors oftheWorld bank or the governments they represent. IFC does not assume any responsibility for the completeness or accuracy of the information contained in this document. Please see the terms and conditions at www.ifc.org/ smartlessons or contact the program at smartlessons@ifc.org. IFC SmartLeSSonS -- JULy 2008 4