Understanding the African Development Bank

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 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 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.

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, SOMO, Oxfam Novib en Recourse hebben een bijdrage ingestuurd op FMO's consultatie over hun Position Statement on Financial Intermediaries. In dit position statement neemt FMO slechts beperkt verantwoordelijkheid voor de gevolgen van haar investeringen via zogeheten financial intermediaries.  We roepen FMO op een position statement uit te brengen dat erop gericht is mensenrechten en milieu wél te beschermen en daarvoor verantwoordelijkheid te nemen.