The undersigned civil society organizations have prepared this joint submission to provide an overview of many of our concerns related to IFC’s Policy on Social and Environmental Sustainability, the Performance Standards, related guidance documents, and the Disclosure Policy. We believe these concerns should be explored and addressed further through IFC’s current consultation and review process.
This review provides an important opportunity to respond to critical developments in the last three years, including, for example, the adoption of the United Nations Declaration on the Rights of Indigenous Peoples by the United Nations General Assembly (UNDRIP); increased progress in understanding the responsibilities of private actors with respect to human rights; increased understanding of the urgent need to respond to climate change; and a significant increase in the development and use of new approaches to lending.
The review also provides a much-needed opportunity to incorporate lessons learned in response to the financial crisis. The crisis underscored the need to provide clear expectations and standards for private sector actors, as well as adequate transparency, due diligence, and oversight procedures to ensure that risks are assessed and addressed fully. We believe the approach assumed by IFC in 2006, prior to the crisis, to introduce greater flexibility in IFC standards and to shift monitoring and supervision responsibilities to private sector clients, is clearly inconsistent with new hard-learned lessons about how to deal with financial risks and poses problems for securing strong development outcomes.