How can the World Bank improve stakeholder engagement in COVID-19 Fast Track Facility projects and beyond?

BIC reviewed a sample of COVID-19 emergency response project documents to assess whether the World Bank was preparing and implementing high quality Stakeholder Engagement Plans (SEPs). BIC’s new report finds several gaps relating to the inclusion of marginalized groups, information disclosure, and grievance redress mechanisms. We propose a series of recommendations the Bank and Borrowers should take to improve stakeholder engagement.

A new report from BIC, “Help or Harm in Times of Emergency? The World Bank’s Commitments to Stakeholder Engagement During COVID-19,” offers insight into the Bank and Borrowers’ efforts to meet stakeholder engagement requirements. The analysis examined project documents from 11 of the 80 COVID-19 Fast Track Facility projects the World Bank has approved since March 2020 and found significant gaps in how documents covered the identification of marginalized groups, meaningful stakeholder engagement, and grievance redress mechanisms (GRM) . 

Through the COVID-19 Fast Track Facility, the Bank has rapidly approved projects designed to help Borrowers improve the availability of medical supplies, strengthen disease surveillance systems, and implement public education and behavior change interventions to promote behaviors like hand-washing and social distancing. Historically, the Bank has viewed health projects as lower risk for environmental and social harm so safeguards application to these projects has been less rigorous. However, findings from BIC’s COVID-19 response project monitoring demonstrate that these projects and other health projects do have a significant risk of harm, particularly where marginalized groups, who may be at greater risk of contracting, or suffering severe cases of COVID-19, are excluded from project benefits.  Conducting meaningful stakeholder engagement and disclosing information about the risks and impacts of the project in accessible formats, as early as possible and in alignment with ESS10, is critical to inclusive project design and implementation.  

Due to COVID-19 restrictions in most countries and the rapid response nature of project creation and approval, face-to-face stakeholder consultation, particularly with marginalized groups, was not always an option in the COVID-19 Fast Track Facility projects. Nonetheless, the Bank still required its borrowers to detail how they planned to conduct meaningful stakeholder engagement throughout the project life cycle in their Stakeholder Engagement Plans (SEPs). In the report, we reviewed a sample of the SEPs to assess how the Bank and its borrowers fulfilled this commitment and understand what measures are being taken to consult stakeholders. From our review of documents, there is no evidence that the Bank or its borrowers prioritized meaningful stakeholder engagement. Specifically, we found shortcomings related to: identification and inclusion of marginalized groups, including Indigenous Peoples (IPs); accessible disclosure of project information; representative GRMs equipped to handle gender-based violence (GBV) and sexual exploitation, abuse, and harassment (SEA/H) related complaints; and, specific budget allocations to implement stakeholder engagement activities.   

While the sample of SEPs we reviewed is not necessarily representative of all the COVID-19 emergency response projects, our findings are instructive in considering best practices for SEPs both for emergency projects and more broadly. BIC recommends the Bank and Borrowers implement the following actions to bring their stakeholder engagement in line with Bank policy and good practice: 

  1. Consistently consider marginalized groups to avoid exclusion. For all projects, Borrowers need to use a clear and consistent definition of “vulnerable” in project documents, as outlined in the Bank Directive Addressing Risks and Impacts on Disadvantaged or Vulnerable Individuals or Groups. This is critical to avoid excluding vulnerable groups from consultation and potentially from project benefits. Especially for emergency projects or those categorized as high or substantial risk, borrowers should hire an independent specialist, who has experience in the project context, to comprehensively identify stakeholder groups and include marginalized communities. For the stakeholders identified, the Borrower should specify plans and timelines for consultations and designate the personnel responsible to implement them.    
  2. Disclose project information in a timely and accessible manner. The Bank and Borrower should disclose project information, including SEPs, in local and official languages well in advance of stakeholder engagement activities. Furthermore, the Bank and Borrower need to make project information available in formats accessible to marginalized stakeholders so they can best understand project risks and voice their concerns. For projects prepared on a rapid timeline, the Borrower should commit to updating the SEP within a concrete timeline and disclosing the updated version to keep project stakeholders informed.
  3. Create culturally sensitive GRMs that are representative of the community and specify how GBV and SEA/H complaints will be addressed. Before project implementation, Borrowers need to seek input from marginalized communities and prioritize representative grievance response committees that include women, individuals with expertise in child protection or child SEA/H, and other marginalized groups. Borrowers also should use consistent terminology to describe both GBV and SEA/H related risks and explicitly state how GRMs are equipped to handle them. As Bank projects and the compounding factors of emergencies like COVID-19 expose children to SEA/H risks, GRMs intended to handle such grievances need to be set up in a child-friendly manner. 
  4. Support the comprehensive implementation of SEPs. To strengthen the application of SEPs throughout the project cycle, Borrowers should include line-item budgets with adequate resources to support all planned activities within the SEP. Moreover, the Bank and Borrowers should specify in the SEP and the Environmental and Social Commitment Plan (ESCP) who is responsible for updating and disclosing the SEPs and when the updated SEP will be disclosed. Consistency of responsibilities across project documents will help prevent the failure to disclose the updated SEP and promote greater accountability. 

Despite the challenge the pandemic presents in engaging stakeholders, meaningful stakeholder engagement in COVID-19 response projects is still crucial, especially as the effects of the pandemic have affected marginalized groups the most. This will not be the last time the Bank and Borrowers are faced with preparing and approving projects on a rapid timeline. At all times and especially during times of crisis, the Bank must uphold its commitments to inclusive stakeholder engagement and prevent the exclusion of marginalized groups, who continue to disproportionately suffer the impacts of emergencies. 

For more information, please read the full report here.

Photo courtesy of Centre for Human Rights and Rehabilitation