How well is the World Bank implementing its Environmental and Social Framework in COVID-19 health response projects?

Meaningful stakeholder engagement and social inclusion are core tenants of the World Bank’s Environmental and Social Framework (ESF), but in practice, these fundamental pieces of the ESF seem to be lacking in COVID-19 health response projects. The Bank must prioritize robust ESF implementation so that everyone, including those from marginalized groups, will be able to benefit from these projects.

The World Bank’s Environmental and Social Framework (ESF) prohibits discrimination against “disadvantaged or vulnerable groups,” such as persons with disabilities, LGBTQI individuals, children, and the elderly. The environmental and social assessment is fundamental to identifying and mitigating any barriers to accessing project benefit and mitigating harm for these groups. However, World Bank project teams have not been prioritizing this aspect of ESF implementation in COVID-19 health response projects, which risks excluding the most marginalized from project benefits. Given the critical role the World Bank is playing in the COVID-19 response, the Bank needs to address this lack of inclusion.

World Bank management and the Board of Directors have traditionally thought of health projects as lower risk than projects in other sectors like infrastructure and historically have not focused enough on the implementation of safeguards for health projects. But excluding groups from COVID-19 health projects risks significant harm and could undermine the goals of the Bank’s COVID-19 response. This is especially true because many marginalized groups are even more susceptible to COVID-19 and its health implications, including death, due to linguistic, cultural, monetary, or physical barriers. Marginalized groups includes migrants or refugees, including those living in crowded camps, those living in orphanages or institutions, those relying on others for personal care such as the elderly and persons with disabilities, and those who might not be able to access information about COVID-19 spread because they do not speak or read the language in which information is being disseminated. 

In the World Bank’s COVID-19 health response projects that BIC has reviewed and monitored in partnership with civil society organizations in Liberia, Uganda, and El Salvador, we are seeing significant, widespread gaps in implementation of the ESF. We are particularly concerned by the lack of specific measures in project documents designed to enable marginalized groups to benefit from these health projects. Without these specific provisions, past precedent suggests that marginalized groups are likely to be excluded from project benefits. Equally importantly, we are seeing a failure to engage in genuine stakeholder engagement. While we understand the barriers created by the pandemic, we are seeing insufficient efforts to engage stakeholders virtually, or through other alternative means, in a timely manner. The consultations and engagement that we have been seeing is delayed until project implementation, and this often does not occur at all absent strong demand from civil society. This last piece is critical because it suggests that stakeholder engagement is worse in the projects which we, and our partners, are not monitoring.

For an inclusive response that adheres to Bank policies and incorporates the needs and considerations of stakeholders, particularly those from marginalized groups, the Bank should take the following steps to strengthen its COVID-19 response. 

1. Identify barriers to project benefit. The social assessment of a COVID-19 health project must identify barriers to project benefits for each “disadvantaged or vulnerable group” and mitigation measures to address such barriers should be developed, in line with Environmental and Social Standard (ESS) 1 of the ESF. It is crucial that this assessment is done before project implementation begins so that marginalized groups can access project benefits from the very beginning.

2. Strengthen stakeholder engagement. Meaningful stakeholder engagement, including with marginalized groups and civil society organizations, should take place during the design phase for all COVID-19 response projects, in line with ESS 10. Carrying out consultations during the design of a project, including with marginalized groups, will help to identify barriers to accessing project benefits, and to develop the mitigation measures necessary to enable these groups to benefit from the project. Failure to consult stakeholders, especially marginalized groups, threatens the success of the project as it can result in gaps in programming. These gaps may be related to inaccessible information, inaccessible hospitals/health centers, and stigma and discrimination preventing some groups from seeking testing and treatment, ultimately resulting in more cases and potentially more deaths. Unless the Bank includes marginalized groups in the process, projects will lack the intended impact of reducing the spread of COVID-19, treating those who contract the disease, or strengthening health systems. 

3. Provide timely, accessible information. In order for stakeholders to have a clear understanding of the full picture of the World Bank funded COVID-19 health response in a country, the Bank should disclose documents for COVID-19 projects in a timely manner, at a minimum, prior to Board approval. These documents need to be accessible to local stakeholders including in the official language(s) of the country, and outline how a COVID-19 health project fits into other health projects in the country, especially when Contingent Emergency Response Components (CERCs) are activated from other World Bank funded health projects in the country. This will allow stakeholders to better understand how basic health service delivery might be impacted by the COVID-19 response and how they can engage around the projects.

Access to information and timely disclosure of documents is even more important now in the time of COVID-19. The shift toward working from home and the lockdowns and travel restrictions in many countries around the world have hampered lines of communication. This has made it difficult for stakeholders to engage and for BIC and partners to get answers to how the Bank and governments around the world will address the impact of COVID-19 on marginalized groups. Access to information is vital for partners to have a better understanding of what a Bank-funded project will be supporting in a country, like supplies such as personal protective equipment (PPE) or ventilators, tests, or COVID-19 education materials, and what the potential risks and mitigation measures will be. 

The World Bank’s ESF provides protections for marginalized groups, requires assessments that specifically evaluate the impacts of the project on each “disadvantaged or vulnerable group,” and requires engagement with stakeholders throughout the process. Unfortunately, in COVID-19 health response projects, assessments, document preparation, and consultations are happening too late in the process, making it difficult to make critical changes in project design. In some cases these things appear to only happen because civil society has engaged and demanded that the Bank and the government uphold the key tenants of the ESF. Leaving groups out or not addressing key barriers to project benefit for communities could be a matter of life and death in these projects. This is especially important as the World Bank begins planning for the next phase of COVID-19 health response — vaccine distribution. 

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