The project "Belarus - Higher Education Modernization" is being implemented by the Ministry of Education of the Republic of Belarus and is financed through an International Bank for Reconstruction and Development loan of 100 million euros. The stated goal of the project is to improve the teaching and learning environment and the information on labor market relevance of higher education. The intended timeframe of the project is 5 years (2020-2025).
The Bank's Social and Environmental Framework document [1] emphasizes the importance of open and transparent communication between the borrower and stakeholders, and the importance of effective stakeholder involvement for successful project planning and implementation. Also, when determining the basis for the partnership between Belarus and the Bank for 2018-2022, [2] the importance of transparency and public participation was emphasized. Thus, the need for more information on public policy decisions and its availability has been highlighted as an overarching priority (paragraph 50). Accordingly, it is logical to expect the implementation of the stated principles in the project of modernization of higher education.
The investment project assessment document on the Bank's website [3] does not contain clear criteria for assessing the transparency of strategic decisions made and their implementation within the project, which would allow sufficient public control over the project. At the same time, control over the Bank's funds spending is regulated by separate procurement regulations, which highlight transparency as one of the key principles. In all matters related to the project, the borrower is solely responsible to the Bank, and the Bank determines the acceptability of the submitted reports. However, all information about the project, procurement, interim reports on the project is provided on the Bank's website in English only. Given the low level of English proficiency in Belarus [4], it can be assumed that this information is not sufficiently accessible to a wide range of stakeholders. At the same time, the information provided on the websites of the Ministry of Education and its subordinate organizations (the National Institute of Education, the National Institute for Higher Education, the Main Information and Analytical Center of the Ministry of Education) is only general and fragmentary, which does not allow to obtain a holistic view of the project, planned activities and course of their implementation. In addition, the information availability raises questions. For example, on the website of the Ministry of Education, the path to information about the project is as follows (Russian language version): Main \ Structure \ Main Department of Vocational Education \ Higher Education \ Investment project "Belarus - Higher Education Modernization".
Besides the Ministry of Education and its subordinate organizations, 18 Belarussian universities are directly involved in the project. Special sections with information about the project have been created on the websites of all 18 universities. The contents of these sections is not systematic. The information on the project and the details of each university's participation in it vary in degrees of comprehensiveness. There is general information about the project, plans for cooperation with stakeholders, information on appeals (complaints) filing mechanism, as well as information on planned activities within the project's framework (13 out of 18 universities are represented to varying degrees). It should be noted that in the overwhelming majority of cases, the description of the planned activities only touches upon one of the project components, namely component 1. Modernization of the teaching and learning environment.
In assessing the risks associated with the project, the risk associated with the stakeholders inclusion and participation was assessed as significant in the Investment Project Appraisal Document. Based on the Bank's Environmental and Social Standard 10 (Standard) [5], which is mandatory, borrowers have developed a general stakeholder engagement plan [6]. However, according to the interim report on the implementation and results of the project dated August 20, 2021 [7], posted on the Bank's website, at the time of its submission, the plan had not yet been finalized. This means that, contrary to the Standard, which sees the greatest benefit from stakeholder involvement in the early stages of project development, the plan was approved one year after the start of the project. According to the information available, the institutions and organizations coordinating the project follow the general stakeholder engagement plan.
The websites of 6 universities (BSTU, BSPU, VSTU, GrSU, VSAVM, BSAA) participating in the project, only present the general plan, the websites of the remaining 12 (BSU, BNTU, BSEU, BSUIR, BrSTU, PolesSU, VSU, PSU, GSTU, BSMU, GrSAU, BelSUT) also present the university's plans for interaction with stakeholders.
Analyzing the list of identified stakeholders, one can note a wide coverage of various groups. At the same time, there are no actual representatives of civil society among the stakeholders. Also, defining the groups too broadly (for example, students, postgraduates, applicants, teachers, employers, etc.) does not allow for effective communication and stakeholders involvement. The definition of vulnerable social groups raises questions. Based on the analysis of the project documents, it can be assumed that project implementers virtually equate this category with people with disabilities, ignoring other vulnerable groups, which does not contribute to greater social inclusion and addressing the problem of gender inequality. A fairly wide range of communication channels is offered for interaction with stakeholders. However, just a few of them allow for bilateral cooperation and not only for informing the stakeholders. The formalism in determining the topics for discussion with stakeholders is also worth noting, as well as the fact that for the overwhelming majority of universities the planned cooperation with stakeholders is limited to a single component of the project, namely component 1. Modernization of the teaching and learning environment.
Stakeholders are not being included in the decision-making process. According to the information available, project work teams have been established in 3 out of 18 universities (BSEU, BSPU, GSTU). It is likely that similar work teams also exist in other universities. However, the composition of the work teams responsible for project implementation raises questions. Based on the analyses of the work teams composition, it can be concluded that their members are the top management of the universities (vice-rectors, deans, heads of departments etc.). Neither teachers, nor students, nor vulnerable groups representatives are involved in the direct management of the project. Moreover, according to the report of the Belarusian Students Association, confirmed cases of political pressure and persecution of students by the university administration took place in 8 out of 18 universities (BSU, BSEU, BSPU, BSUIR, BrSTU, PSU, GrSU, BSMU) (download report), which does not facilitate collaboration with these stakeholders, who are the main beneficiaries of the project. According to the “Honest University” initiative, there is evidence of political pressure and persecution of teachers by the university administration in 13 out of 18 universities (BSU, BNTU, BSEU, BSPU, BSUIR, BrSTU, PSU, GrSU, BSMU, GSU, VSTU, BelSUT, BSTU) (download report).
Information availability and accountability to stakeholders raises questions. The information on activities within the framework of the implementation of stakeholder engagement plans is essentially not disclosed, and there is no reporting to stakeholders as called for in the plan. With the exception of special sections with general information on the websites of universities and other organizations participating in the project, and a few individual reports on focus groups conducted in a number of universities (see below), there is no publicly available information on the progress of the project. Also, the very mechanism of publishing information about the project in the "news" section with its subsequent archiving complicates the access to the information in the future.
In addition to activities within the framework of stakeholder engagement plans, the following three measures are mentioned as public participation mechanisms (paragraph 88 of the investment project appraisal document):
Joint planning through conducting focus groups with students and teachers (of both sexes) participating (as well as students and teachers with special needs).
Annual online student surveys in the framework of "University 3.0" program;
Appeals (complaints) handling mechanism.
The reports on the implementation and results of the project dated 02/25/2021 [8] and 08/20/2021 state that “wide public participation, a well-organized complaint handling mechanism and information activities within the project's framework are key factors for its successful implementation”.
According to the authors of the project, joint planning through frequent focus groups events, as one of the stated mechanisms of public participation, would give students and teachers the opportunity to influence the implementation of activities aimed at modernizing the environment (corresponding to sub-component 1.2 Modernization of the physical environment for teaching and learning) and promote internationalization and mobility (corresponding to sub-component 2.2 Internationalization of higher education). Considering the fact that students and teachers are the main beneficiaries of the project, it is precarious to limit their participation in project planning to two of its subcomponents, as well as not to include them in the work teams in Universities (see above).
Reports on the course of implementation and results of the project from 25.02.2021 and 20.08.2021 have information on the conduct of focus groups for discussion of project activities by the Ministry of Education with teachers and students participating. However, there is no publicly available information on the groups' composition, the issues discussed or the results. At the same time, the websites of some universities involved in the project have the information about focus groups conducted in a mixed format at a later date. BSPU - September 23, 2021, BSTU - September 29, 2021, BNTU - December 10, 2021, BSEU - December 16, 2021, BSU - January 19, 2022, BSUIR - January 26, 2022. There is also information about such an event in GrSU dated October 22, 2021. Based on the analysis of the available information on the above-mentioned "focus groups", it should be noted that the format of the meetings does not correspond to the format of a research method, so the use of this term by project participants is controversial and misleading. It is noteworthy, that all these meetings were attended by representatives of the Bank, the events were held in the capital's universities (except GrSU) and in late 2021 - early 2022. Given the lack of information on the conduct of other focus groups, it is impossible to determine whether the stated frequency was complied with.
As another mechanism of public participation, the authors of the project present annual online student surveys in the framework of the University 3.0 program. The survey aims to assess whether the educational environment stimulates the development of entrepreneurial skills. Within the project, these surveys are used for gathering information on the changes in the educational environment and giving recommendations, which means that this mechanism was not intended for bilateral cooperation with the option of an open discussion of the project. In addition, it should be noted that the development of the educational environment is only one of the four components of the project (component 1. Modernization of the teaching and learning environment). Information on the use of this mechanism within the project is not publicly available.
The project documentation also calls for stimulating the appeals (complaints) handling mechanism ensuring its accessibility within the project, as well as annual publication of reports on received appeals (complaints). In addition, the need to ensure the availability of a mechanism for filing appeals (complaints) is emphasized in Annex II (Part C, paragraph 3) to the loan agreement [9], which obliges the borrower "to hear and determine fairly and in good faith all complaints raised in relation to the Project, and take all measures necessary to implement the determinations made by such mechanism in a manner satisfactory to the Bank''.
The mechanism for reviewing appeals (complaints) within the project is implemented on the basis of the Law of the Republic of Belarus of July 18, 2011 №300-3 "On appeals of citizens and legal entities'' [10]. The websites of the organizations and universities involved in the project contain contact information of persons who can be contacted and inquired about the project and the procedure for submitting and reviewing applications by responsible persons. However, the websites of 6 out of 18 universities (BSEU, BSPU, BSUIR, GSTU, BSMU, BSAA) lack this information. According to the information available, in two universities (BSU, BNTU), in accordance with the Bank's recommendations, in order to strengthen the complaint handling mechanism, logs of appeals (complaints) were established within the project [11]. During the analysis of publicly available information, it was found that some of the institutions took no other measures to encourage a wide range of stakeholders to participate in the project and express their opinions on its implementation, apart from informing about the possibility of submitting appeals. At the same time, the formalistic approach to appeals consideration of public authorities and institutions, as evidenced by the correspondence between the European Students' Union and the Ministry of Education, calls into question the adequacy and effectiveness of the feedback mechanism proposed for the project by its implementers. The annual report on appeals handling provided for in the project documentation is not publicly available.
Thus, having analyzed the available information on the project "Belarus - Higher Education Modernization" on the matter of implementation of the principles of transparency and public participation, we can draw a number of the following conclusions.
Although some attention was paid to ensuring transparency in the implementation of Bank-financed projects, the lack of clear criteria for its evaluation in terms of planning, decision-making and reporting allows the borrower to disregard this requirement. Getting a holistic view of the project is difficult, information is not presented systematically, but in fragments, in some cases the information is not easily accessible. Particular attention should be paid to the limited information available on the components 2. Innovation in teaching and learning, 3. Quality assurance, 4. Project management. Despite the fact that the project provides for a number of public participation mechanisms, their adequacy to the objectives set and especially their implementation raise questions. Untimely development of stakeholder engagement plans suggests a low level of stakeholder involvement in the project planning phase. Stakeholders identification lacks specificity, vulnerable groups are virtually equated with persons with disabilities. Many of the provided mechanisms of public participation are of a formal nature, aimed only to inform stakeholders and not providing for bilateral cooperation and stakeholder participation in decision-making. The reporting provided for in the plans is de facto missing.
[1] The World Bank. 2016. World Bank Environmental and Social Framework. World Bank, Washington, DC. https://thedocs.worldbank.org/en/doc/837721522762050108-0290022018/original/ESFFramework.pdf
[2] World Bank Group. 2018. Country Partnership Framework for the Republic of Belarus for the Period of FY18-22. World Bank, Washington, DC. https://openknowledge.worldbank.org/handle/10986/29703
[3] Belarus - Higher Education Modernization Project (English). Washington, D.C.: World Bank Group. http://documents.worldbank.org/curated/en/868901590285670943/Belarus-Higher-Education-Modernization-Project
[4] According to the 2009 census, only about 5% of the population of Belarus is fluent in English. There are no more up-to-date data. Population census, 2009: [statistical compendium] / National Statistical Committee of the Republic of Belarus. V. 3: National composition of the population of the Republic of Belarus).
[5] The standard is part of a framework document on social and environmental issues developed by the Bank. 2016. World Bank Environmental and Social Framework. World Bank, Washington, DC. https://thedocs.worldbank.org/en/doc/837721522762050108-0290022018/original/ESFFramework.pdf
[6] the Ministry of Education of the Republic of Belarus. 2021. Stakeholder engagement plan.
https://adu.by/images/2022/01/plan-raboty-zaineresov-storonami.pdf
[7] Nikolaev, Denis. Disclosable Version of the ISR - Belarus Higher Education Modernization Project - P167992 - Sequence No: 03 (English). Washington, D.C.: World Bank Group. http://documents.worldbank.org/curated/en/ 692501629464360127/Disclosable-Version-of-the-ISR-Belarus-Higher-Education-Modernization-Project-P167992-Sequence-No-03
[8] Nikolaev, Denis. Disclosable Version of the ISR - Belarus Higher Education Modernization Project - P167992 - Sequence No: 02 (English). Washington, D.C.: World Bank Group. http://documents.worldbank.org/curated/en/ 423031614258590596/Disclosable-Version-of-the-ISR-Belarus-Higher-Education-Modernization-Project-P167992-Sequence-No-02
[9] LEGKL. Official Documents - Loan Agreement for Loan No. 9056-BY (English). Washington, D.C.: World Bank Group. http://documents.worldbank.org/curated/en/798231600177780089/Official-Documents-Loan-Agreement-for-Loan-No-9056-BY
[10] The law of the Republic of Belarus of July 18, 2011 №300-3 “On Appeals of Citizens and Legal Entities”
https://pravo.by/document/?guid=3871&p0=h11100300
[11] Example of appeals (complaints) registration log within the project at the Belarusian National Technical University. https://static.bntu.by/bntu/new/files/file_4507f7bb19323d2e8402e90f4064e070.docx
A similar log was established at the Belarusian State University.
ANNEX 1: exerpt from BSA report on violations (download)
ANNEX 2: repressions statistics from Honest University (download)