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Third World Network

From the Arab Revolutions to Global Austerity


by Third World Network

3 May 2013

Dear friends and colleagues,

To highlight some of the complex dynamics and challenges of the IMF’s role in the Arab region, in a context of continuing popular uprisings that are calling for social and economic justice and for transforming the national development paradigm, and to link it to the waves of austerity across Europe, the US and other regions, a panel discussion titled “From the Arab Revolutions to Global Austerity,” was held on the sidelines of the spring meetings (19-21 April) of the IMF and World Bank.

The event held on 20 April was organized by Third World Network and Arab NGO Network for Development, in cooperation with Cairo-based Egyptian Center for Economic and Social Right and Initiative for Policy Dialogue at Columbia University in New York.

We are pleased to share with you a report of the panel discussion in two parts. In Part I below we report the presentations of Manuel Montes from South Centre (Geneva) and Isabel Ortiz from Initiative for Policy Dialogue.

Part II will report on the presentations of Mahinour El Badrawi from Egyptian Centre for Economic and Social Rights (Cairo) and Kinda Mohamadieh from Arab NGO Network for Development (Beirut).

With best wishes,
Third World Network

TWN Info Service on Finance and Development (May13/01)
5 May 2013
Third World Network
www.twn.my


From the Arab revolutions to global austerity Will the peoples’ uprising fall on deaf ears in the current wave of austerity?

PART 1

Washington, D.C., 2 May (Bhumika Muchhala and Kinda Mohamadieh) - The post-revolution Arab region has been high on the recent agenda of the International Monetary Fund (IMF).

Besides its annual Article IV, or macroeconomic assessment reports, which prescribes national policy blueprints, the IMF has been engaged in the region in a variety of ways. Morocco and Jordan have two-year loan packages, Yemen has an emergency credit line and Tunisia just recently signed on to a precautionary financing arrangement. Meanwhile, Egypt is in the throes of contentious negotiations with the IMF country mission team on its loan programme.

These programmes are designed with detailed policy conditionality on various fronts, including fiscal policy, with a region-specific focus on fuel subsidies, monetary and exchange rate policy, and structural policy related to domestic labour markets. Trade liberalisation, privatisation, public-private partnerships, financial and banking policies are also part of the loan packages. The IMF’s role in the region is only amplified by its historical links to bilateral donor and capital market financing.

To highlight some of the complex dynamics and challenges of the IMF’s role in the Arab region, in a context of continuing popular uprisings that are calling for social and economic justice and for transforming the national development paradigm, and to link it to the waves of austerity across Europe, the US and other regions, a panel discussion titled “From the Arab Revolutions to Global Austerity,” was held on the sidelines of the spring meetings (19-21 April) of the IMF and World Bank.

The event held on 20 April was organized by Third World Network and Arab NGO Network for Development, in cooperation with Cairo-based Egyptian Center for Economic and Social Right and Initiative for Policy Dialogue at Columbia University in New York. The IMF-World Bank meetings are held twice a year in Washington, D.C., and involve the chief finance ministry and central bank officials from the member states of those Bretton Woods Institutions.

The discussants of the event included Manuel Montes from South Centre, Isabel Ortiz from Initiative for Policy Dialogue, Mahinour El Badrawi from Egyptian Centre for Economic and Social Rights, Kinda Mohamadieh from Arab NGO Network for Development and Bhumika Muchhala from Third World Network, as chairperson of the panel.

To open the session, Bhumika Muchhala said that there is a problematic paradox between the endeavors of the international development community to formulate a Post-2015 global development agenda and the global consensus on austerity, particularly in the form of public spending cuts and regressive tax policies. Both sides of the Mediterranean are facing similar macroeconomic stability programmes that prioritize deflationary macroeconomic policies over expansionary ones that could stimulate public investment, create urgently needed jobs and re-orient tax policies toward wealth redistribution for greater socioeconomic equality.

The Arab region is already facing a troubling degree of macroeoconomic instability in public and private debt, fiscal imbalances and foreign reserves. Fiscal consolidation can carry many risks, such as exacerbating youth unemployment, reinforcing economic inequalities and various social discriminations and deepening economic and financial dependency on external donors and creditors. This would, in tragic irony, lead to a re-creation of the same unjust and failed economic model that led to the peoples uprisings over the last several years. The peoples’ revolution in the Arab region was not merely a reaction to corrupt dictatorships, but also the outcome of unjust and failed economic and social models. In this sense, the aspirations and demands of the people are directly connected to international financial and trade regimes, in that systemic policy-setting and rules impact national outcomes.

Austerity goes against the very grain of development strategy, said Muchhala. A development strategy involves a pro-active and developmental state that builds a social contract with citizens and possesses the policy space and political will to implement transformation processes that are structural, institutional and normative. This includes, for example, directing public expenditure and investment toward building strong social sectors, particularly in health, education and social protection; creating decent work through strategic sectoral investments, boosting wages and strengthening productive capacity; ensuring food security and economic self-resilience against volatile global commodity prices.

Manuel Montes, Senior Financial Advisor in the South Centre, said that Arab countries confront both political transition and economic recovery, and it is not clear if one will support the other or whether the nature of the economic recovery would facilitate or hinder political transition, or even if economic recovery will be consistent with a change in growth dynamics that will avoid a repeat of the economic crisis.

These processes of transitions, according to Montes, involve the geopolitical and commercial interests of external donors, with international financial institutions serving as the technocratic policy channel for donor interests, along with the old and newly emerging domestic forces.

A similar intervention by international financial institutions was witnessed in the Philippines’ transition during the 1986 overthrow of former President Ferdinand Marcos, which took place in the midst of the 1982 debt crisis (which swept through Latin America and many African countries). Montes explained that the World Bank and the IMF economic conditions in the new government were based on a “selective debt repudiation.” This was a condition that mandated the servicing of public debt inherited from the previous government. Having been intimately connected with this previous government, the IMF and WB staff made strenuous efforts to rehabilitate the reputations of their agencies, which began to be seen as playing a dual role of both upholding corrupt authoritarian or strongman regimes and then attempting to aid a ‘democratic transition’ after their overthrow.

Montes said that some of the major Arab countries today face severe balance of payment crises, including Morocco, Tunisia, Egypt, and Jordan. These countries have been facing current account deficits during the last three years along with elevated debt levels, and austerity is being proposed as the way towards stabilizing the macroeconomic situation in the region.

Montes explained that the IMF programs are based on a “backward calculation”, whereby the focus is placed on the financing gap of the coming 12 to 24 months, with the most important claim on resources being the amount of debt servicing that can be extracted from public revenues and domestic private savings, with an emphasis of maintaining the Fund’s own parameters of ‘debt sustainability.’

Meanwhile, the implicit assumption remains that a restructuring of external debt is not on the table as an option. Thus, the level of domestic growth that can be afforded is discussed within the context of the previous two considerations. Within this approach, economic recovery and the absorption of unemployed capital and labor become the residual result after debt servicing is prioritised.

Montes highlighted that the problem with the word austerity is that it implies that everyone’s spending is cut. However, the way austerity often plays out in reality is that households, factories and their workers (e.g. the real economy), and the public sector face spending cuts while creditors, donors and the financial sector receive payments owed to them at market interest rates that are contractually due. Unlike in developed countries where perhaps austerity has some element of social psychology to try to motivate a well-developed private sector to begin taking risks and making investments again, in developing countries austerity is not done for its own sake - it is done to set aside resources to ensure repayment of debt owed, Montes added.

Thus, the IMF’s financial loans to a country often stands for helping the country to meet its external debt service obligations, Montes explained. It also means that it is not the country that is being rescued, it is rather the creditors and institutions who have outstanding debt owed to them. In the meantime, under these programs with the IMF, the government must undertake austerity-driven policy reforms whose long-term impact on investment and growth has proven to be highly doubtful in previous experiences.

For example, measures, such as removing fuel subsidies should be a medium-term and long-term undertaking done with proper deliberation. Only if resources saved from the immediate elimination of such subsidies are guaranteed to be applied to employment and job creation, and not debt servicing, can the removal of fuel subsidies be a legitimate part of an emergency strategy.

IMF interventions are associated with recommendations for ambiguous but large-scale terms such as “enabling environment,” which often translate into blanket investor protections and straitjackets on capital controls that unduly restrict growth oriented domestic policies. Such policies tend only to elicit short-term, speculative investments from abroad. It does not create the platform for long-term and sustained public investment that creates jobs and spurs new economic activities. Th e impact of policy restrictions in favour of “enabling environments” could also mean loss of control over domestic interest rates and lending and the exchange rate, which amplifies risk and obstructs long-term investment.

Yet, Montes said that countries have multiple alternatives to consider. Countries could “calculate forward” instead of backwards, by identifying how much of the factories and workers are idle, the rate of macroeconomic growth that would be required to re-absorb unemployed resources, and the investment rate that will absorb new entrants into labor force and improve the competitiveness of the economy over the medium-term.

Countries can also consider monetary easing, in the same way that advanced economies are doing, Montes highlighted. However, this will require imposing or re-imposing capital controls to maintain adequate control over exchange rates and domestic interest rates.

Such heterodox policy programmes would require up-front debt restructuring given the debt load of many countries in the Arab region, which has the potential to pave the way toward national development strategies that open up political space and re-shape the terms of relation with external financiers.

Montes questioned whether Arab countries in the post-dictatorship context are facing “choiceless democracies”. Under such a context, even though a democratic processes is introduced, the choices for economic programmes are still deeply limited. Thus, the policy agenda carried out is often a continuation and acceleration of the old government’s agenda, even though the old rulers have already been overthrown.

On the way forward, Montes argued that the alternative to fast growth associated with greater inequality and higher or more vulnerable unemployment is slower but sustained growth, with less vulnerable employment, less subjection to cyclical and volatile booms and busts, and more protection of the livelihoods of the poor and the middle classes. Such growth protects domestic policy space and permits the government to implement policies to protect employment and simulate investment in new more productive jobs. Montes reminded the participants that experience in the past showed that the cost of the bust (which also lasts many more years) exceeds the benefits from the boom. For example, twelve years after the financial crisis, Southeast Asian investment rates have not recovered the levels they averaged before the crisis.

Montes concluded by noting that there are alternative policies, but only a genuinely functioning democracy, based on a social contract of accountability and dialogue with citizens, would allow such alternative policies to emerge.

Isabel Ortiz, Director of the Global Social Justice Program at the Initiative for Policy Dialogue, presented a critical paper, titled ““The Age of Austerity - A Review of Public Expenditures and Adjustment Measures in 181 Countries.” She stated that contrary to public perception, austerity measures are not limited to Europe; in fact, many adjustment measures feature most prominently in developing countries. According to IMF data, 119 countries will be adjusting public expenditures in 2013, increasing to 131 countries in 2014 and the trend will continue at least until 2016.

Ortiz noted that there are two main phases of the global crisis. In a first phase (2008-09), most governments introduced fiscal stimulus programs and ramped up public spending. However, premature expenditure contraction became widespread in 2010, despite vulnerable populations’ urgent and significant need of public assistance.

Fiscal contraction is most severe in the developing world. Moreover, comparing the 2013-15 and 2005-07 periods suggest that a quarter of countries are undergoing excessive contraction, defined as cutting expenditures below pre-crisis levels.

In terms of population, austerity will be affecting 5.8 billion people or 80% of the global population in 2013; this is expected to increase to 6.3 billion or 90% of persons worldwide by 2015.

Regarding austerity measures, a review of IMF country reports published between January 2010 and February 2013 indicates that governments are weighing various adjustment strategies. These include: (i) elimination or reduction of subsidies, including on fuel, agriculture and food products (in 100 countries); (ii) wage bill cuts/caps, including the salaries of education, health and other public sector workers (in 98 countries); (iii) rationalizing and further targeting safety nets (in 80 countries); (iv) pension reform (in 86 countries); (v) healthcare reform (in 37 countries); and (vi) labor flexibilization (in 32 countries).

One of the most alarming trends in austerity policies worldwide is that of subsidy reduction and elimination, even in a global context of high food prices. The report highlights that subsidy reduction, primarily in fuel but also in electricity, food and agricultural inputs like seeds, fertilizer and pesticides that can sustain local production, is occurring across approximately 100 countries (78 developing and 22 high-income).

However, if basic subsidies are withdrawn, food and transport costs increase and can become unaffordable for many households. Higher energy prices can also contract economic activities. Increased hunger and malnutrition has irreversible impacts on children. Ortiz recalled that in recent years, food protests have erupted in Algeria, Bangladesh, Burkina Faso, Egypt, India, Iraq, Jordan, Morocco, Mozambique, Nigeria, Senegal, Syria, Tunisia, Uganda and Yemen, to name but a few.

In order to achieve “cost-savings,” cuts or caps to the public wage bill, the public purse from which salaries of public employees are drawn, are on the rise as well. In most developing countries, civil servants as well as teachers, doctors, nurses receive their salaries from the public wage bill. Ortiz said the report demonstrates that the recurrent expenditures of salaries in the public wage bill are being reduced, cut, eroded in real value or capped in 98 countries, including 74 developing and 23 high-income countries. Payments in arrears, hiring freezes and/or employment retrenchment are also taking place, all of which can adversely impact the delivery of public services.

Ortiz stressed that 94 countries (63 developing and 31 high-income) are considering options to boost revenue by raising Value-Added Taxes or sales tax rates or removing exemptions. However, increasing the cost of basic goods and services can erode the already limited incomes of marginalized groups and stifle economic activity. Since this policy does not differentiate between consumers, it can be regressive, shifting the tax burden to families in the bottom income quintiles of society and exacerbating inequalities. Alternatively, progressive tax approaches should be considered, such as taxes on income, inheritance, property and corporations, including the financial sector.

Pension reforms are being considered in 86 countries (47 developing and 39 high-income) and involve measures such as raising pension contribution rates, increasing eligibility periods, prolonging the retirement age and/or lowering benefits.

Health system reforms are taking place in 37 countries (12 developing, 25 high income), involving the increase of fees and co-payments paid by patients along with cost-saving measures in public health centers. The main risk of these two adjustment measures is straightforward: vulnerable groups are excluded from receiving benefits or assistance is diminished at a time when their needs are greatest.

Ortiz also noted that 80 countries (55 developing and 25 high-income) have been rationalizing or further targeting social safety net systems. The IMF’s policy prescriptions generally associate targeting social programs to
poverty reduction, including in countries with large populations below the poverty line, where the logic of targeting to the poorest of the poor is weak. Overall, policymakers should consider that, in times of crisis, it is important to scale up social investments instead of scaling down. A strong case can be made to extend a social protection floor for children, elderly, persons with disabilities.

The worldwide propensity toward fiscal consolidation can be expected to aggravate the employment crisis and diminish public support at a time when it is most needed. It is imperative that policymakers recognize the high human and developmental costs of poorly designed adjustment strategies and consider alternative policies that support a recovery for all persons.

The paper, which is co-published by IPD and the South Centre, is available at:
http://policydialogue.org/files/publications/Age_of_Austerity_Ortiz_and_Cummins.pdf

PART 2

The involvement of International Monetary Fund in the post-revolution Arab region was the focus of discussion at the panel discussion titled “From the Arab Revolutions to Global Austerity,” held on 20 April on the sidelines of the spring meetings of the IMF and World Bank in Washington D.C.

Morocco and Jordan have two-year loan packages, Yemen has an emergency credit line and Tunisia just recently signed on to a precautionary financing arrangement. Meanwhile, Egypt is in the throes of contentious negotiations with the IMF country mission team on its loan programme.

The first two presenters on the discussion panel were Manuel Montes from South Centre (Geneva) and Isabel Ortiz from Initiative for Policy Dialogue (New York) - see Part I of this report.

Mahinour El Badrawi from the Egyptian Center for Economic and Social Rights discussed the IMF policy recommendations to Egypt before the 2011 revolution and the current negotiations between the IMF and Egyptian authorities around a new loan. Shortly after the toppling of the Mubarak regime, an IMF team started negotiations of financial assistance to Egypt, which was presented as a step for stabilizing the Egyptian economy and promoting needed structural economic reforms. The proposed loan is of the value of USD 4.8 billion.

El Badrawi said that the terms of negotiations of loan are not made public or undertaken in a transparent way. The national economic plan presented to the IMF was not made public except after civil society organizations brought forward a case in front of the national administrative court requesting transparency in the terms of negotiations with the IMF.

El Badrawi noted that IMF loans are often presented by the country teams as free of conditions and based on ‘home-grown’ economic plans. However, the economic plan released by the Egyptian authorities in November 2012 mirrored the policy recommendations that came in the IMF Article IV consultation report for Egypt, released in April 2010. This IMF report advanced recommendations for broadening the tax base through expanding the application of the regressive value-added tax, and through cuts to the fuel and food subsidy programs.

The IMF Article IV report also advanced recommendations for the resumption of privatization processes while encouraging public-private partnerships. These recommendations were reflected in the economic plan of the Egyptian authorities made public in November 2012.

El Badrawi noted that the reforms proposed within the framework of the discussions with the IMF were to be carried out on both the average Egyptian and the well-off investors. On subsidies’ reform, they were supposed to be lifted from heavy industries besides the energy use of the households. Similarly, the tax rise was supposed to be implemented on business transactions and capital gains. Yet, what actually took place was the removal of subsidies from household energy use, which increased 150% from 3 to 8 Egyptian pounds, besides the removal of subsidies on basic food products. Other planned reforms on business transactions and investors were not implemented.

Overall the ‘reforms’ are falling disproportionately on the average Egyptian and the poor. The official explanation presented for not undertaking the other reforms is declared to be an attempt not to scare away investors. In the same line, the Egyptian Security Council of Armed Forces undertook a legislative change after the revolution through issuing Law #4 for year 2012, giving immunity for investors found to be corrupt or in violation of national law from being sued in national courts and substituting that with a mediation procedure undertaken by the executive body (ministry) that was responsible for designing the contract with the investor in the first place.

Such steps, El Badrawi explained, features into the past cycle of marginalizing productive investments and economic patters. Furthermore, it hinders the process of retrieving national assets and resources that were ill-used under the previous regime. Under such anti-developmental legislative framework, the sort of investor that is being invited into Egypt would reproduce the cycle of weakening chances for real productive development.

El Badrawi highlighted alternatives for the kind of austerity-focused reforms that are currently designed, which carry a burden that disproportionately falls on the average Egyptian citizen. She indicated the need for progressive taxation systems, including a non-fixed progressive corporate tax that supports small and medium enterprises.

She also highlighted the importance of recovering the stolen assets of the country, which are the peoples’ assets. Furthermore, she addressed the importance of recovering the value of the national assets and state-owned enterprises, which have been de-valued and privatized under the previous regime.

Kinda Mohamadieh from the Arab NGO Network for Development discussed the structural policy advice advanced by the IMF country reports on Arab countries. Mohamadieh cautioned that the IMF continues to advance recommendations for reducing or dismantling tariffs, widening the scope of liberalization, and de-regulation under investment policy.

Furthermore, such trade and investment related policy advice could often fall in contradiction with safeguarding these countries’ balance of payments positions, thus leading them into more exposure to debt accumulation and need for IMF assistance. Such longer-term structural change restricts the policy space of governments to design a dynamic longer-term plan that serves production, industrialization, decent employment, and social justice.

Mohamadieh explained that economic and social challenges facing Arab countries include the challenge of reversing the declining trends in productive capacities and share of wages in gross domestic product, along with redesigning macroeconomic policies in support of a longer-term dynamic development project.

While many Arab economies experienced an average annual real economic growth above 5 percent during the last 20 years, growth in productivity was less than half of that and negative in some cases. Many Arab countries have witnessed significant decline in manufacturing capacities, and deindustrialization trends in many Arab countries, most notably Egypt and Morocco. Overall, the structural economic problem in the region has been stagnating shares of agriculture and manufacturing, and rapidly expanding concentration in low value added services activities.

Wage depression, reflected in the regress of wages as a share of national income, has been associated with the kind of investment and trade policies that have been followed, which prioritized export-oriented sectors. This wage depression reflected the violations of economic and social rights and the marginalization of the citizen participation in the economic cycles and national growth trajectories.

Foreign direct investment (FDI) has also been traditionally concentrated in low job generating sectors, like mining and real estate. Overall, the role of macroeconomic policies in supporting a longer-term development-oriented strategy was neglected. Macroeconomic policies were re-oriented to prioritize short-term inflation targeting, attracting foreign direct investment, and increasing openness to trade and capital flows. Arab countries need a reverse of these trends, and a revival of productive capacities, employment generation, and redress of inequalities and wage depression.

Mohamadieh highlighted that the IMF is the same institution that was lauding Tunisia’s and Egypt’s sound macroeconomic management and structural reforms, just a few month before the peoples’ revolutions in these countries. The IMF even called for more austerity measures to contain public spending on wages and food and fuel subsidies at a time these countries were facing rising food prices due to global pricing fluctuations.

After the revolutions, the IMF along other international financial institutions involved in the Arab region were quick to present the policies undertaken during the last two decades as too partial to take real hold given the decline in legitimacy of state, corruption and nepotism. This argument was central for presenting the shortcomings of the economic model they promoted to previous regimes as stemming from its application within undemocratic and oppressive contexts, and not, as a failing of the economic model itself.

Shortly after the revolutions, in its report entitled “Economic Transformation in MENA: Delivering on the Promise of Shared Prosperity” presented to the G8 Summit in May 2011, the IMF advanced recommendations for liberalization of trade in services, liberalization of capital flows and investment, freedom of establishment, and regulatory convergence in areas such as competition policy, trade and investment regimes, public procurement.

The Report’s recommendations included as well calls for further improving the business climate, which are centred around promoting more investment zones where investors are credited with lower regulation and taxation, as well as strengthening investor rights.

Similar recommendations were presented in 2013 by the Director of the IMF’s Middle East and Central Asia Department, thus advancing recommendations for further dismantling tariffs and widening the scope of liberalization, along with de-regulatory recommendations in investment, including removing the barriers to starting or closing a business, and relaxation of entry requirements, minimum capital requirements and restrictions on foreign ownership, along with removing exit regulations and decriminalizing business failure [1].

Mohamadieh noted that the vision presented to the region is one of deeper liberalization and deregulation, without serious assessment of the implications that such previous policy experiences have reaped for the region. Such line of recommendations has been consistently advanced through staff country reports (Article IV consultation reports) before the global crisis, and before the revolutions in the Arab countries, as well as afterwards.

Mohamadieh highlighted that in 2009, the Independent Evaluation Office [2] of the IMF published its evaluation report on the IMF involvement in international trade policy issues. The report highlighted that the “interventionist approach of the late 1990s, when the IMF played an uneven but at times aggressive role in trade policies through conditionality, gave way to substantial reluctance to state strong positions even on trade policies that have macroeconomic import” [3].

The report importantly noted that “on some issues- particularly PTAs and trade in services stand out- the objectives and approach for IMF involvement were not made clear (by the IMF Board). Nor were the criteria for macro-criticality that were to guide staff decisions on when to become involved in trade policy issues. Without such clarity, staffs are unlikely to be effective in looking out for trade policy -related threats to macroeconomic and financial stability” [4]. The report specifically highlighted the IMF’s role and recommendations in regard to trade in financial services, whereby the IEO report noted that IMF bilateral surveillance in this area “was less thorough, tending indiscriminately to urge greater openness to foreign financial service providers with little direct assessment of risks” [5].

Mohamadieh noted that trade policy is not neutral in terms of impact on balance of payments, especially when imports rise disproportionately to the rise of exports. In such context, countries face tighter external constraints, decrease in revenues, larger trade deficits and thus dependency on capital inflows, leading them into potential increase in external debts.

Furthermore, the deregulatory recommendations on the investment policy front contradicts the need to actively redesign investment policies in the Arab region to support a developmental trajectory, and achieve an active interface between foreign direct investment, capital formation, and advancing of national private enterprise and national productive and industrialization capacities. Without addressing the nature and orientation of FDI, rapid flow of capital and over-concentration of FDI in non-tradable sectors could hold significant impacts on the balance of payment positions of these countries.

Overall, the design of structural policy recommendations advanced by the IMF in the Arab region lock the economies of the region in a state of dependency and weaken the domestic productive capacities. It would not allow the design of trade and investment policies in a way that supports and allows for the revival of productive and employment generating capacities. Besides limiting the policy space available for governments to dynamically use trade and investment to support industrialization and employment generation, it could also have significant destabilizing implications at the macro-economic level, especially on the balance of payment position of these countries.+



[1] Masood Ahmed (March 2013); “Toward Prosperity for All- Finance & Development,” March 2013, Vol. 50, No. 1

[2] The IEO was established in 2001 with the task of undertaking independent evaluations on issues related to the IMF. According to its self-presentation: the “IEO operates independently of IMF management and at arm’s length from the IMF Executive Board”. See page iii of the report (2009) on IMF involvement in international trade policy issues produced by the IEO.

[3] IEO report, Chapter seven on “Findings and Recommendation”.

[4] IEO report, Chapter seven on “Findings and Recommendation”.

[5] IEO report, Chapter seven on “Findings and Recommendation”.


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