Under its most recent global strategy, the World Bank committed to ramp up and systematize its citizen engagement efforts, citing research showing that effective citizen engagement contributes to increased positive development results. Consistent with this commitment, the Bank is poised to approve a draft Environmental and Social Framework (ESF) containing a brand new policy on Stakeholder Engagement and Information Disclosure. If approved, 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.
The World Bank lends to dozens of client governments with varying capacity to implement projects in accordance with the Bank’s high environmental and social standards. When it comes to engagement with stakeholders in particular, 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 Bank’s proposed 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 draft 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 would 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 be mandated to develop and disclose to stakeholders a full, comprehensive, and stand-alone SEP.
Finally, 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.