Joint Submission of comments and recommendations to the Public Consultation on AfDB Integrated Safeguards System

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.

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 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, 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.

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.