Comments to AIIB’s Energy Strategy: Sustainable Energy for Asia Issues Note for discussion

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.

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.

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.

Het Mandalika International Street Circuit is een straatcircuit in de badplaats Mandalika in Centraal Lombok in de provincie West Nusa Tenggara. Het project, dat vooral bedoeld is om toeristen aan te trekken, wordt grotendeels gefinancierd door de Asian Infrastructure Investment Bank (AIIB), waarin ook Nederland een aandeel heeft.

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.

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.