As envisaged in the Code of Conduct, the IMF has in place a system of ethical conduct certification and financial disclosure. This system was first introduced in April 2000 and since then has been updated on several occasions and expanded, including in 2021 when the ethical conduct and core values certification replaced the financial certification, and most recently in June 2023 when the IMF decided to publish summary statements on its external website of the financial interests reported by the Managing Director and the Deputy Managing Directors.

While management has full confidence in the integrity of staff, it attaches the utmost importance to ensuring and being able credibly to demonstrate that the International Monetary Fund (IMF) has in place internal control measures to prevent conflicts of interest. As the IMF is at the forefront of international efforts to improve governance and gives advice to member country governments in this area, it is particularly important for the IMF to act in accordance with best practices.

All Fund employees are expected to avoid conflicts of interest between their personal interests, including financial interests, and their work for the Fund, and to comply with the system of ethical conduct certification and financial disclosure, including the reporting of full and accurate information where required. While the requirement to submit an annual ethical conduct certification has been extended to long-term contractual employees of the Fund, the requirement to file an annual confidential statement of financial interests and activities does not apply to contractual employees of the IMF.

The main features of the current system are as follows:

• All staff and long-term contractual employees regardless of grade level are required to submit an annual ethical conduct and core values certification. Through this exercise, staff and long-term contractual employees certify on an annual basis that they have read and are in compliance with the Fund’s N-Rules, the Standards of Conduct, including the Framework on Financial Disclosure and Financial Conflict of Interest, and the Fund’s Code of Conduct. They also certify that they have read and will act in accordance with the Fund’s Core Values. The certification is to be submitted every year to the Ethics Office through the Fund’s electronic people management system.
• All staff at Grades A15 and above, as well as other designated staff, are required to complete, on a confidential basis, an annual financial disclosure form.
  • Through this program, covered staff submit every year an annual financial disclosure form with information on financial assets, real estate, and liabilities as of December 31 of the previous year and information on selected financial transactions for the relevant period.
  • The confidential financial disclosure forms are submitted through an electronic platform and reviewed by the Fund’s External Compliance Advisor. The External Compliance Advisor reviews independently the information disclosed in the forms, seeks clarification or additional information from the staff member as needed, and seeks to resolve any potential, apparent or actual conflict of interest, consulting where appropriate with the Fund to implement recommended remedial action.
  • Staff who participate in the annual financial disclosure program also submit at the time of their separation from the Fund a disclosure statement addressing any changes in their financial interests since their last annual statement.
  • Based on the confidential financial disclosure forms, summary public statements of the financial interests reported by the Managing Director and the Deputy Managing Directors are published on the Fund’s external website at the conclusion of the year’s confidential program. These public statements, remain for the duration of the appointment of the Managing Director and two years thereafter and for the duration of the appointment of each DMD and six months thereafter.
• Outside of the annual financial disclosure program, paragraph 27 of the Code of Conduct already establishes the requirement that any staff member who considers that he or she might be in a position of actual or apparent conflict of interest at any time should disclose the matter to his or her supervisor or to the Ethics Officer (see below). This requirement is an important additional safeguard for the IMF and staff members.
• Fund employees who wish to seek advice on potential conflicts of interest should contact the Ethics Advisor or –- to the extent related to the annual financial disclosure submission -- the External Compliance Advisor.