Letters

Today, almost 90 organisations and networks from around the world, including Both ENDS, sent a letter to the European Commission to urge the EU to stop including UPOV91 in Free Trade Agreements (FTAs). The main objective of UPOV91 is to further erode traditional seeds rights and to regulate local seed markets in the interest of internationally operating seed companies.

This matter is urgent because currently, the EU and Indonesia are negotiating an FTA. Including UPOV91 in this FTA means that Indonesia will have to change its policies, which will take away the farmers' rights to:

- breed, save and exchange all seeds and other planting material
- participate in decisions concerning seed improvement/ breeding, selection, quality standards, pricing, production, distribution and diversity
- customary practice especially in regard to indigenous seed
- be protected from being sold fake and inappropriate seed
- have a true choice between the use of certified and seed from fellow farmer managed seed systems.

Both ENDS, SOMO, Oxfam Novib and Recourse sent in a submission to FMO's public consultation on its Position Statement on Financial Intermediaries. In this position statement, FMO only takes limited responsibility for the consequences of its investments through so-called financial intermediaries.  We call upon FMO to publish a position statement that focuses on protecting human rights and the environment and take full responsibility for this.

Pesticide Action Network and 430 civil society and indigenous peoples organizations from 69 countries have sent a letter of concern to the 170th session of FAO council about the FAO partnership agreement with CropLife International.

CropLife International is a global trade association whose members are the world's largest agrichemical, pesticide and seed companies: BASF, Bayer Crop Science, Corteva Agriscience, FMC Corporation, Sumitomo Chemical and Syngenta. The UN Food and Agricultural Organisation (FAO) en CropLife International have started a partnership in 2020 to collaborate on pesticide use. We think that this partnership is incompatible with FAO's obligations to uphold human rights, directly counters any efforts toward progressively banning Highly Hazardous Pesticides, and undercuts the FAO and several Member States' support for agroecology and other transformative practices.

The letter asks the Council to review and end immediately the partnership agreement with CropLife International.

This letter by Both ENDS to the African Development Bank is a comment written in reaction to a draft version published by the Bank of its Environmental and Social Policy as part of a formal public consultation held by the Bank. This comment was sent to the bank along a joint submission letter with other CSOs, and specifically responds to the overarching Policy.

The bank's flexible requirements for clients and national standards for risky projects dilute safeguards. Project approval should be predicated on specific and binding targets for compliance and reflect input from communities involved.

Together with 29 other CSO's, we've submitted our comments and recommendations in the Public Consultation on the AfDB Integrated Safeguards System. These include that the Bank should prioritize community-led development and human rights-based approaches; protect natural resources and tackles environmental and climate crises; raise the bar on access to information, transparency and accountability; facilitate participatory processes in policies, programmes and projects; and end inequality, poverty, and the cutback and privatization of vital services.

Both ENDS, also on behalf of FERN, NCIV and Milieudefensie, sent a letter to Vivianne Heijnen, the State Secretary for Infrastructure and Water Management, about the MTCS certificate. In practice, this Malaysian timber certificate appears to tolerate the violation of indigenous land rights and intimidation of indigenous organisations. The Netherlands should therefore suspend the approval of MTCS in its purchasing policy, among other things.

6 civil society organizations, including Both ENDS have submitted a gender comment on the newly proposed EIB Environmental and Social Framework. The EIB Environmental and Social Standards has to be updated to ensure that due attention to gender specific impacts, risks and related mitigation strategies is integrated in the policy and each standard, as well the assessment needs to specifically address the needs and problems of all genders. A lot of improvements can be made in the integration of gender aspects in policy and standards, in order to prevent violation of the rights of women and girls during project implementation, and tools (widely used by other organisations) and or commitments for their development should be included (inclusive consultations, Gender assessments and analyses, gender impact assessment, Legal Assessment Tool (LAT) for gender-equitable land tenure, gender responsive tools for prevention of violence.

This briefing of Eurodad, co-authored by Pieter Jansen, Both ENDS aims to outline recommendations on how the European Investment Bank should address the interconnected issue of gender inequity and the climate crisis in the newly proposed environmental and social policy.Severe climate change has consequences for human rights, including the right to life. As such, under the European convention on human rights the EIB has a duty to stop carbon-emissions related investments. The EIB and project promoters must monitor a project's greenhouse gas emissions and the climate risks of the project on the natural environment, and the women possibly affected by the project. The newly proposed policy should ensure that project promoters, who apply for EIB funding, submit a gender and social inclusion plan, and full participation and engagement of women, local communities and stakeholders in the Climate Risk Vulnerability Assessment methodology.

16 civil society organisations including Both ENDS have written a letter of concern to the European Investment Bank about a newly proposed standard for the Bank its intermediate finance investing. Both ENDS contribution to the contents of the joint letter consists out of proposals for improvement of screening, scoping, due diligence, appraisal, monitoring and supervision of high-risk clients and sub-projects. through financial intermediaries and clear and mandatory social, environmental and human rights requirements for FI investing matters.

25 civil society organisations, including Both ENDS have submitted a comment on the overarching policy of the newly proposed Environmental and Social Framework of the EIB Group. The EIB has to undertake environmental, climate, social and human rights assessment and appraisal of proposed projects to inform the decision of financing and must not rely on a clients' self-assessment and reporting (solely). The Policy needs to state clearly what the due diligence, monitoring and reporting responisibilities for the EIB are, in particular regarding human rights and contractual clauses with clients should enshrine the standards in all EIB operations, enabling for suspension of contracts if the standards are not implemented.

Both ENDS and partners gave their input on FMO's public consultation on Climate Action Commitments and Fossil Fuel Statement. Both ENDS and partners are pleased that FMO is finally taking a stand regarding fossil fuels, but in our opinion it could be more ambitious.