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EBRD safeguard policies

NGOs have consistently criticised the EBRD for a number of weaknesses in its safeguard policies, deficencies resulting in many cases from the limited public involvement in the Bank’s decision making processes. While the EBRD made some concrete steps forward by approving a revised Public Information Policy (PIP) and Environmental Policy (EP) in 2003, and introducing its Independent Recourse Mechanism (IRM) in 2004, these revised policies are still far from sufficient and Bankwatch intends to propose further changes.

Public Information Policy


The Public Information Policy is the fundamental framework for providing access to information at the EBRD and governs the Bank’s interaction with the public. The PIP is necessary to establish transparency and accountability of the institution and foster public participation in decision making processes.

On March 1, 2006, the EBRD announced its third review of the PIP. Although civil society groups proposed recommendations to make the consultation process more inclusive, the Bank offered only one draft for public comments- limited to a period less than 60 days- and failed to organize face to face meetings with a wide array of stakeholders to discuss the policy. As a result, civil society groups were limited in contributing thoroughly and effectively during the policy consultations. The rushed revision of the policy resulted in the inclusion of only one NGO recommendation in the final policy; the remaining changes to the policy were drawn from the draft presented by EBRD Management.

The new Public Information Policy does take some positive steps to enhance transparency and good governance at the EBRD. These measures include the disclosure of draft Country Strategies, minutes of Board of Directors meetings, salaries for senior staff, Directors and the president, a rolling list of upcoming policies and strategies to be reviewed and a blacklist of clients engaged in corruption and fraud. The Bank also amendmended the regime of exceptions to disclose information and agreed to translate project summary documents in local languages. However, recommendations touching on principles of the access to information and Board transparency were not reflected. Furthermore, due to time constraints the Bank decided to develop procedural provisions for information requests and appeals outside of the April/May 2006 PIP review. Civil society groups are therefore calling on the Bank to conduct a comprehensive PIP review in 2007.  Further recommendations from civil society include:
  • Narrowing the regime of exceptions to cases when disclosure poses a serious risk of harm to a legitimate secrecy interest, and that it includes a public interest override.
  • Increasing transparency of Board discussions.
  • Disclosing more public and private sector project documents, including private sector project Board reports, investment contracts, supervision and monitoring reports, and a list of financial intermediary sub-projects
  • Disclosing e-mail, telephone and fax contacts of all EBRD staff, especially Executive Directors
  • Making a schedule of visits by the President, Executive Directors and senior management to countries of operation available in a timely manner.
Fundamental to a potential policy review in 2007 is the pressing need for the EBRD to adopt the recommendations from the “Almaty Guidelines on Promoting the Application of the Principles of the Aarhus Convention in International Forums”. The Aarhus Convention Principles are now becoming benchmark principles for all international forums. As such, Board discussions related to the environment (such as debates on environmental and information policies, discussions on category A projects) ought to be accessible to the public.

Current Information Policy and Procedures

Citizens Guide

Environmental Policy and procedures


Given the EBRD´s mandate, the Environmental Policy is a key document guiding the Bank’s promotion of sustainable development. The policy defines procedures the EBRD should follow to ensure that its operations are environmentally sound. As a review of the EP approaches towards the end of 2006, civil society groups have raised concerns about the lack of robust social safeguards within the policy. These minimum benchmarks are necessary to properly assess project impacts on the livelihoods of communities. In addition to these concerns, other improvements needed include:
Environmental Impact Assessment (EIA) documents for private sector projects should be released 120 days prior EBRD Board approval, as currently happens with public sector projects.
  • Full environmental analyses for Category “B” projects should be disclosed, as Category “B” projects may have significant impacts on the environment
  • Public hearings must be a mandatory part of the public consultation process
  • Projects that involve potential social, health and labour impacts should be subject to a detailed Social Impact Assessment.
  • Audit reports on social and environmental issues in the proposed project areas should be made publicly available.
  • EIAs for all projects should be done in a comprehensive manner and, as with sectoral and regional assessments, focus particular attention on cumulative impacts. The practice of splitting the project into phases should be officially banned.
  • The proposed policy should include the phase-out of financing activities with potential negative environmental impacts (e.g. cyanide bleaching technologies in mining activities).

Current Environmental Policy and Procedures

Citizens Guide

Independent Recourse Mechanism

The EBRD was one of the last development banks to set up a compliance mechanism. Unfortunately, during the preparation of its Independent Recourse Mechanism (IRM), the EBRD decided to ignore the experiences of similar institutions and as a result has created a very narrowly defined and legalistic mechanism.

Bankwatch is monitoring various cases that have been submitted to the IRM, and we provide recommendations for citizens on how to go about using this mechanism. As things stand currently, we will be making suggestions for further improvement of the mechanism when it comes to be reviewed.

IRM procedures and guidelines