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Executive Directors and Civil Society Roundtable at the 2014 World Bank Spring Meetings.
Transparency, participation and inclusion are essential aspects of development work. The World Bank professes to embrace these principles, but in practice has come up short in ensuring that accessible information and opportunities for engagement are provided to all those who have a stake in its development projects.
Over the years, the World Bank has made undeniable improvements in transparency and engagement, which in large part are a result of constructive dialogue between civil society and the Bank. For example, in 2010, the Bank adopted its Access to Information Policy, which codified access to vital information for civil society and affected communities around the world. Sustained advocacy by civil society around these issues has also resulted in a Stakeholder Engagement safeguard policy, which will require borrower governments to engage with stakeholders throughout the investment project cycle, rather than just at the outset.
While BIC welcomes the new Environmental and Social Standards on Information Disclosure and Stakeholder Engagement (ESS10), and other efforts at enhancing participation and inclusion that the Bank has made in recent years, we believe its policies and practices in this area could be further strengthened. Stakeholder engagement is an important cross cutting theme across all of BIC’s thematic issue areas as well as our regional work. See below for more information about BIC’s work in this area—including model policy language and model methodologies for engaging with vulnerable and marginalized groups.
Community discussion on a World Bank Inspection Panel case in Egypt
What are the major issues surrounding information disclosure and stakeholder engagement?
Current World Bank Safeguard policies do not set out clear requirements for project oversight, reporting, upstream engagement, stakeholder outreach and inclusion, timely information disclosure, or accessibility of grievance mechanisms. All of these requirements surrounding transparency and participation are essential to the ability of civil society to engage with World Bank projects and policies.
For instance, the timing of information disclosure is key to civil society’s ability to respond meaningfully to published documents. If information is not disclosed until a project is well under way, it is unlikely to improve the public’s ability to engage with its implementation. Inadequate timing can render information disclosure useless as a tool for participation and engagement.
In addition, borrowers are not currently required to disclose (let alone promote) the existence of the World Bank Inspection Panel. This makes it unlikely that communities and civil society organizations will be aware of how to express their grievances and change the course of World Bank projects.
Safeguards consultations themselves exhibited problems relating to the timing of disclosure of meeting times and locations, their openness to civil society, and the quality of information provided. For instance, specific consultation details were often given on extremely short notice and with little clarity on who can participate and how. Some consultations have been by invitation only, with no public criteria for invitees. While the Bank has made strides in ensuring that consultations are accessible and inclusive, some consultations were in spaces that are not accessible for persons with disabilities. The geographic reach of consultations was significant, but not adequate enough to involve stakeholders who cannot access major cities.
How can information disclosure and stakeholder engagement at the World Bank be improved under the new Environmental and Social Framework?
The Bank has approved an Environmental and Social Framework (ESF) containing a brand new policy on Stakeholder Engagement and Information Disclosure. The new policy will require borrowers for the first time to engage with project stakeholders in all types of investment lending projects funded by the World Bank. However, several loopholes could leave stakeholders vulnerable to negative impacts and retaliations. In order for the new policy to allow for effective and meaningful engagement with impacted communities and project stakeholders, the Bank must increase its supervisory role, particularly for the highest risk projects and for those taking place in countries where communities and civil society may have limited capacity and space to operate.
When it comes to engagement with stakeholders, many governments do not have the national systems and requirements in place to conduct meaningful, accessible, and safe consultations with impacted communities and project stakeholders. In fact, in some of the Bank’s client countries, civil society and communities who have voiced concerns over development project impacts have faced retaliation by their governments. In the ESF, the borrower government will be responsible for identifying the stakeholders who should be engaged in each project. This risks that those who would raise critical issues or dissents would be excluded in the interest of a speedy and less costly process. To avoid this dangerous situation, the Bank must oversee the stakeholder identification process with independent specialists for all projects that warrant a High or Substantial risk categorization.
Under the ESF, the borrower government will also commit to developing and disclosing a Stakeholder Engagement Plan (SEP) when receiving financing for a project from the World Bank. The SEP will lay out the borrower’s plans for engaging with stakeholders throughout the project life cycle. However, a loophole may exempt borrowers from developing and disclosing this full plan in some situations. This provision is presumably meant to allow for flexibility for small or short term projects that are not expected to have significant impacts, but it could allow even the highest risk projects to proceed without this documentation. To ensure effective stakeholder engagement, projects of High and Substantial risk level must develop and disclose a full, comprehensive, and stand-alone SEP.
As procedures and guidance for implementing this new policy are developed, it is critical that the Bank heed its own advice and continue to take input from those who are best placed to provide it – civil society and stakeholders themselves.
Safeguards Review Documents
Recommendations regarding the World Bank’s proposed Environmental and Social Standard 10 (March 2016)BIC Recommendations regarding child rights related elements of World Bank Draft Environmental and Social Standards (March 2016)
ESS 10 Information Disclosure and Shareholder Engagement – Redlined Policy Phase 2 Submission (August 2015)
BIC’s Guide to a First Look at the World Bank’s Revised Environmental and Social Framework (August 2015)
BIC Recommendations regarding: World Bank Draft Environmental and Social Standard 10 on Information Disclosure and Stakeholder Engagement (March 2015)
Civil Society Comments on the Draft Environmental and Social Framework – ESS10 and Implications on Accountability (March 2015)
BIC Notes on ESS 10 (Oct 2014)
Consultations Accessibility
BIC Children’s Consultations webpageObstacles to Participation in World Bank Safeguards Consultations (Bank on Human Rights, Nov 2014)
Information Disclosure
BIC Access to Information at the World Bank webpageWorld Bank access to information website
Jolie Schwarz
Child Rights Program Associate
+1 (202) 624-0621
jschwarz@bicusa.org Amy Ekdawi
Regional Programs Director
+1 (202) 624-0620
aekdawi@bankinformationcenter.org