More than thirty years ago, in response to disastrous effects of its development projects, the World Bank Group (WBG) instituted the first of eight safeguard policies designed to "prevent or mitigate adverse impacts of its projects on people and the environment." These policies formed the bedrock of a rules-based, "do no harm" approach to development that "improved significantly" the WBG's ability to mitigate social and environmental risks, according to its Independent Evaluation Group (IEG).
Yet because these policies were decades old, all agreed that they required significant updating. Beginning in the summer of 2012, the World Bank undertook a process to review and update the safeguards. After a four-year process of consultation, protest, and compromise, the World Bank's Board of Directors has approved a new, comprehensive, Environmental and Social Framework (ESF) that many see as a shift away from the rules based approach and a threat to the ability to effectively manage the significant risks posed by Bank projects.
The Bank argues that a more flexible approach will modernize the policies and bring the Bank in line with the Busan Partnership on Effective Development Co-operation, which highlights the importance of cooperation and country ownership of development efforts. Such an adaptive model moves the Bank away from a top down, donor driven model towards a locally driven model with the capacity to respond to individual country context--a fundamental premise of good development practice.
However, the lynchpin of a successful, adaptive model is genuine understanding of local context, which requires the voices of civil society and communities to be at the heart of the development agenda. Context--in all its complexity--is not something that the Bank can understand based solely on engagement with its client governments, and the Bank has not excelled in listening to these alternative voices. When the World Bank plans and implements projects based upon faulty assumptions of local context, those projects frequently cause significant harm to local communities, including, in particular, the poor and marginalized among them.
This type of harm was tragically manifested in the Bank's Uganda Transport Sector Development Program (TSDP). The Uganda project was cancelled in December 2015 after reports were substantiated that workers were sexually abusing teenage girls. The cancellation of the project, and the presence of more than two dozen new teenage mothers in a rural community in Uganda, cannot be seen as effective development. The situation could have been avoided had the Bank designed the project to respond to local context, but there was no open channel of communication between the Bank and the local community that would have brought these issues to light when they first arose. Ironically, the Bank's independent Inspection Panel sent the Bank's Board of Directors its investigative report of this project on the same day that the new "flexible" safeguards were approved.
Similarly, at a time when civil society, the European Union, the United States government, and numerous United Nations bodies were condemning the Uzbek government's systematic use of forced and child labor for the harvesting of cotton, the World Bank, following the lead of the Uzbek government, promoted an agriculture project that contributed to the forced labor system. In project documents, the Bank dismissed the possibility of contributing to child labor through the project. Rather, the Bank stated that the risk was that "NGOs will continue to raise the issue of child labor." As long as NGOs are seen as part of the problem rather than part of the solution, the Bank will fall short in catalyzing the institutional and societal reform that is critical to generate growth and reduce poverty.
In the absence of effective citizen engagement, it was the rules-based system of the safeguards, with the World Bank's Inspection Panel ready to hold management accountable, which provided a remedy for those harmed. Under the new, more flexible approach of the ESF, it is unclear how the Bank will ensure that communities do not continue to suffer the same harms as those in Uganda, Uzbekistan and elsewhere.
The Bank has not performed any better in listening to outside voices at the policy level, as evidenced by the final draft of the ESF that was approved yesterday. While the Bank has touted the unprecedented number of consultations held, individuals who participated, and input received, this is not the appropriate measure of inclusivity. The critical question is: how are those contributions taken into account? The final ESF does not appear to have taken on board the vast majority of the input provided by civil society, with Bank management instead clearly prioritizing the desires of client governments.
For the new, more flexible approach to be successful, the views of communities and civil society must be prioritized. It is participation by communities and civil society that ensures adaptive learning is "citizen centric," leading to change that benefits the poor and marginalized. The Bank must address its internal issues and incentive structures to ensure that all projects emphasize the importance of meaningful engagement with communities and civil society. The foundations of this new level of communication are present in the new ESF under Environmental and Social Standard 10--the first safeguard policy on stakeholder engagement--and it is clear that many within the Bank genuinely see citizen engagement as a critical element of effective development. The Bank can start demonstrating this commitment now by better integrating the participation of civil society and communities, along with those of think tanks, International NGOs, and UN bodies, in the process of implementing the new ESF to ensure it is responsive to the needs of those it seeks to protect.
Co-authored with Elana Berger, Child Rights Program Manager at Bank Information Center