In 2019, the African Development Bank Group (AfDB) mandated an independent evaluation of its Integrated Safeguards System (ISS) to assess the effectiveness of the ISS in achieving its objectives. The Independent Development Evaluation (IDEV) function’s report recommended updating specific components and provisions of the ISS as well as improving its implementation to better address relevant emerging safeguards issues. Now that the AfDB has commenced a review of the ISS, BIC and our civil society partners are calling for the AfDB to develop a process that is transparent and inclusive.
The current ISS has five operational safeguards requirements: environmental and social assessment; involuntary resettlement and land acquisition; biodiversity, renewable resources, and ecosystem services; pollution prevention and control, hazardous materials and resource efficiency; and, labor conditions, health, and safety. While borrowing countries and companies are expected to meet these requirements when addressing social and environmental impacts and risks in projects, the AfDB is responsible for performing due diligence and enforcing compliance with these requirements during project preparation and implementation. The IDEV report identified a lack of transparency in relation to environmental and social (E&S) safeguards compliance in Implementation Progress and Results Reports (IPRs) as well as “serious deficiencies in the Bank’s archiving system of E&S documents to verify the operations’ compliance with the requirements of the ISS over the project cycle”.  The report recommends strengthening the quality of AfDB’s E&S work, addressing the needs of marginalized groups, improving stakeholder engagement practices as well as developing the internal and external capacity to foster a common understanding of the ISS process and the actions required to achieve its objectives.
The AfDB’s review of its ISS provides an opportunity for the AfDB to develop a stronger and more effective safeguards system by addressing the recommendations made in the IDEV report and integrating external stakeholders’ feedback on the policy. However, this requires robust and meaningful engagement with civil society. The AfDB does not appear to be prioritizing this engagement as it has only disclosed minimal information about the review and the AfDB has not given any indication that it will hold civil society consultations prior to the development of an initial draft. Civil society engagement prior to commencing the process will enable the AfDB to harness civil society’s input regarding the consultation format and the external stakeholders to consult. It will also provide an opportunity for the AfDB to incorporate initial concerns and comments into the draft, thereby promoting inclusion and participation in the process.
To align with international best practice and achieve these outcomes, the AfDB should promote transparency and accountability and provide inclusive and meaningful opportunities for civil society and communities to input into the review. In a June 2021 letter, 57 civil society organizations (CSOs) from 21 countries urged the AfDB to:
- Publicly disclose information about the review, including the timelines, a consultation plan, and an overview of the scope on its website and on other relevant platforms.
- Organize a robust, meaningful, transparent, and inclusive consultation process, which not only engages a wide range of relevant external stakeholders, including communities and rights holders affected by AfDB funded activities, and their CSO partners, but also provides adequate periods for providing comments.
- Adopt key recommendations from the IDEV report, including strengthening the content and guidance of safeguards components, improving E&S impacts and risks management across project cycles, and reinforcing the readiness review process to achieve compliance with project and ISS requirements, among others.
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 IDEV Report, September 2019, page 5