In December 2013, the African Development Bank (AfDB) adopted its current environmental and social safeguard policies, known as the Integrated Safeguards System (ISS), becoming operational in July 2014. In December 2021, the AfDB publicly announced a review of the 2013 ISS, based on the findings of the Independent Development Evaluation (IDEV) Unit’s 2019 assessment of the ISS’s effectiveness. The report identified some significant issues and gaps in the ISS regarding stakeholder engagement practices, the integration of marginalized groups (including persons with disabilities), gender inclusion, addressing gender-based violence (GBV), and insufficient compliance with environmental and social safeguards. The IDEV report concluded that the AfDB should improve its implementation of the ISS and recommended updating specific components and provisions within it.
Earlier this year, civil society organizations raised a number of priorities for management to consider in the updated ISS though the AfDB’s public consultation process. As the updated ISS is presented to the AfDB Board of Directors for approval, civil society hopes that the Board will endorse a final policy that:
- Takes an integrated, systematic, and consistent approach to the inclusion of marginalized groups, including children and persons with disabilities. Civil society has called for the updated ISS to include a single, consistent definition of marginalized groups that specifically references children, persons with disabilities, and other groups. For more information, read BIC’s submission, which includes comments on the ISS’s approach to marginalized groups, here.
- Prevents and responds to child SEA/H. We hope to see a final ISS that protects women, girls, and children from sexual exploitation and abuse/harassment (SEA/H) and gender-based violence (GBV) by including provisions for handling GBV and SEA/H cases in all project Grievance Redress Mechanisms (GRMs) and developing additional guidance for AfDB staff and the Borrowers on how to put in place effective prevention, mitigation, and response measures that combat the risks of child SEA/H in AfDB-funded projects. Other IFIs, such as the World Bank and ADB, are working towards addressing SEA/H in development projects, the AfDB should quickly follow suit given that Africa ranks highest in child SEA/H. For additional information, read the joint civil society comments on the draft ISS, calling for the AfDB to take a child rights approach.
- Includes persons with disabilities. Civil society expects to see a final ISS that specifically and explicitly refers to persons with disabilities, as well as includes a definition that is in line with the United Nations Convention on the Rights of Persons with Disabilities (CRPD) and the African Charter on Human and Peoples' Rights on the Rights of Persons with Disabilities. To read civil society’s detailed comments and recommendations on the inclusion of persons with disabilities in the draft ISS, read the letter from the disability community here.
- Expands protections for workers. Civil society hopes to see the updated ISS align with international labor standards and have called for management to eliminate the category of “community workers” in the updated ISS in order to expand the protections that apply to some of the most marginalized groups of workers.
- Takes a zero tolerance position on reprisals against project stakeholders. We hope to see the Board affirm an institutional commitment to protecting stakeholders from reprisals in the revised ISS. Civil society have called for the updated ISS to clearly state the AfDB’s zero tolerance for reprisals. For further details, read the joint civil society recommendations on reprisals in the ISS here.
- Addresses climate change in a proactive and progressive manner that aligns with international standards. Civil society hopes that the updated ISS explicitly and specifically includes consideration of climate impacts and requires a climate change assessment (CCA) of all activities proposed for AfDB financing to promote sustainable, sound, and climate resilient impacts. To read BIC’s specific recommendations for a climate change assessment policy, read Annex 2 of BIC’s comments on the draft ISS.
- Protects biodiversity and critical habitats. Civil society has called for the updated ISS to include an expanded definition of “critical habitat” that includes 1) areas recognized by international biodiversity-relevant conventions and agreements, 2) IUCN Designated Areas (Categories IA – VI), and 3) protected or at-risk marine or coastland ecosystems, including mangrove forests, wetlands, reef systems. We hope to see the scope of OS6 specifically address all projects that impact local and indigenous communities and forest dependent peoples, and safeguards their natural resources.
- Provides a detailed plan and appropriate resources for implementation. The updated ISS will represent a significant progression for the AfDB in terms of necessary due diligence, Borrower support, and supervision requirements. However, broadening the scope of the ISS in order to incorporate additional social issues, including ones that impact children, will require the development of new staff capacity, expertise, and training for existing staff at both headquarters and country offices. Meanwhile, the AfDB’s current capacity to supervise Borrowers’ compliance with existing safeguards is already stretched thin. We hope that the Board and management’s discourse following the approval of the updated ISS will include serious consideration of the additional budgetary and capacity requirements that will be needed to adequately implement the updated ISS. Without additional resources, any advances in the new policy will not be realized at the project level, perpetuating dangerous compliance gaps.
Read the detailed civil society submissions below:
Public Consultation on AfDB Integrated Safeguards System Joint Submission of comments and recommendations, May 2022
BIC Comments on Draft Updated AfDB ISS, Bank Information Center, May 2022
Civil Society Comments on Draft Updated AfDB ISS: Taking a Child Rights Approach, May 2022
Comments on the Draft Updated AfDB ISS from the Disability Community, May 2022
Comments on the issue of reprisals in the AfDB ISS Review Process, Defenders in Development Campaign, May 2022