Comments on the EBRD safeguard policies

Policy comments    |    11 April 2018

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Relying on its experience in monitoring EBRD projects in recent years, Bankwatch re-assessed the EBRD Public Information Policy (PIP) and Environmental and Social Policy (ESP).

1. EBRD Public Information Policy (PIP) 2014
   1. General comments
   2. Specific comments
   3. Annex
2. Environmental and Social Policy (ESP)
   1. Part 1: Experience of ESP implementation from energy and agribusiness projects
   2. Part 2: Safeguarding Human Rights. Why the EBRD’s Environmental and Social Policy needs Human Rights Due Diligence?

The 2014 PIP brought with it some innovations in terms of information disclosure, but experience shows that there is still work to be done in ensuring the public has access to information about projects financed and potentially financed by the EBRD.

For the 2014 ESP, improvements in current provisions implementation and further tightening are needed. The EBRD should regulate its financial intermediaries, as delegation does not appear to be working well by itself. The EBRD is encouraged to integrate IUCN Motion no.26, which, among other things, calls on governments to prohibit environmentally damaging industrial activities and infrastructure development in all IUCN categories of protected areas.

While the Policy recognises the responsibility of the bank’s clients and promoters to respect and safeguard a limited number of human rights, the EBRD’s role and specific commitments to human rights protection remain declaratory and vague. The Policy would benefit greatly from introducing the concept of Human Rights Due Diligence (HRDD). HRDD, as a distinct part of social due diligence, can ensure financial and social sustainability of the EBRD’s investments by identifying and managing potential financial, legal and reputational risks for projects.