Letters

Both ENDS submitted a public comment on the proposed access to information policy of the Asian Development Bank. In the regime of exceptions and limitations to the disclosure policy, we are concerned about the lack of a clear requirement for the Bank to adequately justify exceptions. We would prefer the regime of exceptions and limitations to be based on the principle that access to information may be refused only when the Bank can adequately demonstrate harm that may be caused by disclosure.

A letter written by Both ENDS, co-signed by 350.org, Australia, Urgewald, Germany, Green Alternative, Georgia, and others, with comments to the AIIB's Energy Strategy Issues note. This strategy prioritizes large scale energy infrastructure, which fails to meet the energy needs of local communities.

The AIIB has the opportunity to champion financing green energy systems for future generations by leapfrogging the large energy infrastructure that rely on fossil fuels, plantations for biomass or dams.

Both ENDS letter to the World Bank on the Environmental and Social Safeguards policies review. The World Bank safeguards review is part of a reorganization that aims at making lending cost-effective with less rules in place, which likely entails an increase in the number of problem projects. The reorganization aims at making lending
more cost-effective, forms in place. Safeguards policies are of crucial importance for project affected people to hold banks to account. However, Environmental and Social Frameworks (ESF) nowadays replace safeguards at banks. The ESF model leads to a reduction of a Bank's direct and mandatory role in overview, including due diligence, monitoring, and evaluation, of Bank funded activities and investments, along with a shift towards a greater reliance on client self-assessment and self-reporting. Our main ask is a return to binding, rules-based safeguards policies at banks.

Both ENDS co-wrote a Joint CSO Submission on the Draft Revised Version of the EIB Transparency Policy to the EIB. The transparency policy does not adequately reflect key international standards and principles regarding transparency, as set out in the Global Transparency Initiative's Transparency Charter for International Financial Institutions.

The policy should meet the nine key principles as set out in the Global Transparency Initiative's Transparency Charter for International Financial Institutions, namely: 1) the right of access,; 2) automatic disclosure,; 3) access to decision-making; 4) the right to request information; 5) limited exceptions; 6) appeals; 7) whistleblower protection; 8) the promotion of freedom of information; and 9) regular review.