NGO Comments ​on Safeguard Policies & Project Implementation

Upward Harmonization 

The development of new environmental and social safeguards could provide a welcome opportunity to upgrade and strengthen protections at to ensure that the lives and livelihoods of vulnerable communities are, indeed, safeguarded from harm caused by large-scale investments.  The AIIB has pledged strong environmental and social protections and the World Bank has pledged not to weaken or "dilute" existing safeguards.

The Financial Times has presented an analysis by Director of the ADB's Independent Evaluation Department of substantial concerns about World Bank and AIIB new draft safeguards, including the move toward client self-assessment and self-monitoring.

Unfortunately, however, the current draft AIIB safeguards appear weaker than those of their counterparts, including those at the AIIB's regional "neighbor", the Asian Development Bank and those of other multilateral institutions. (See AIIB: NGO Comments page.)

At the World Bank, the Safeguards Review process is being used by Bank management to spark a "race to the bottom" in an attempt to water down existing safeguards to the level of the weakest safeguards available elsewhere, and even weaker than those. Instead of using this opportunity to harmonize World Bank Safeguards with the highest and strongest safeguards, including those at other multilateral financial institutions, Bank management have cynically used the term "harmonization" as a cover for diluting the Bank's safeguards to the weakest standards of other institutions.

March 2015, Ulu Fnd Bankwatch article ADB WB AIIB safeguards 3 15.pdf , Lessons learned? The implications of the ADB's review of Safeguard policy implementation for the World Bank and the Asian Infrastructure Investment Bank. Other models for Bank Safeguards?,  Ulu Foundation in Bankwatch, NGO Forum on ADB, 3/15

Asian Development Bank's Independent Evaluation Department slams World Bank Safeguard Review, ADB IED Press Release. (pdf, IED website). Stating that the World Bank's Safeguard Review process has led to "aspirational" safeguards instead of clear and mandatory requirements and  "could dilute the strength of environmental and social protections" globally, the ADB's IED called for the World Bank to ensure "continued use of a requirements-based safeguards system." 11/11/14

ADB leads push for requirements-based safeguards, DevEx, 11/12/14

ADB Safeguards Operational Review: ADB Processes, Portfolio, Country Systems, and Financial Intermediaries. ADB IED, 10/16/14. 

In October, 2013 over 200 NGOs working with Jubilee South - Asia/Pacific Movement on Debt and Development to monitor the development of safeguards for the Green Climate Fund proposed a model for safeguarding communities and the environment based on the "do no harm" principle  as well as drawing on and strengthening the highest existing safeguards.  This Peoples' Safeguards model provides an overview of important principles to be used in the development of safeguards to ensure that international financial flows meant ostensibly for poverty alleviation and environmental protection do no harm.

After years of advocacy by groups affiliated with the NGO Forum on the ADB, the Asian Development Bank's Safeguards Policy Statement  contains, in certain areas, stronger safeguard language than that of existing World Bank safeguard as well  the Bank's new draft safeguards for financial intermediaries, consultation with affected communities, and gender.  The World Bank new draft ESF safeguards have, so far, failed to "harmonize" with the ADB's higher standards, including the ADB's requirement that local communities which will be significantly affected by Bank projects, must have the right to comment upon environmental and social impact assessments 120 days prior to the Board vote.