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					                    Platform for ‘Rights, Rules and Responsibilities’
                           for IFC’s Safeguard Policy Review

                                           November 2004

The International Finance Corporation (IFC) has provided more than $40 billion directly to private
companies, many of them multinational corporations operating in developing countries, in the name of
sustainable development and poverty reduction. The IFC is also involved in the lending of billions of
additional dollars through its financial catalyst role. This money often goes to projects that lead to
environmental pollution and degradation, poverty creation and more social inequities.

The IFC argues that it brings environmental and social expertise and improves high-risk projects and that
without its involvement, projects would be much worse. However, internal studies and independent
evaluations carried out by affected communities and civil society organizations demonstrate serious and
systemic problems with implementation of the institution‟s environmental and social safeguard policies.
It is also doubtful whether the best use of public funds for development and poverty alleviation is to
mitigate the negative consequences of these high-risk projects rather than invest in projects that have
clearer development benefits.

This past experience demonstrates the need for clear and enforceable rules for IFC lending and significant
institutional reforms to guarantee due diligence, ensure effective implementation and improve
accountability to affected communities and citizens. The proposed policies do not address these concerns,
but instead opt for more flexibility and subjectivity. We oppose this approach and call upon the IFC to
upgrade and strengthen its social and environmental policies and ensure that multinational corporations
respect fundamental international human rights, labor rights and environmental law as conditions for
access to IFC loans.

Global public institutions must operate for the public good. We call for the IFC to abide by clear,
mandatory Rules, Rights and Responsibilities (RRR) to promote the public good through its lending.

The IFC‟s Safeguard Review Process must address current problems of implementation of the safeguard
policies, guarantee that there is no backsliding or weakening of existing policies as well as lead to the
strengthening and improvement of environmental and social policies. The undersigned civil society and
Socially Responsible Investors call on the IFC and its Board of Directors to adopt the following points.


1. Adopt Policy and Performance Standards that establish clear, binding rules and meet the highest
social and environmental standards for IFC and its borrowers, which would allow the IFC to claim
leadership in international standard-setting and demonstrate its commitment to respect international
human rights and environmental laws.

2. Commit and hold itself accountable to deliver on poverty reduction and sustainable development.
One of IFC‟s core responsibilities must include evaluating each and every project it considers for
financing to determine how and whether poverty reduction is likely to occur, stating specifically how
poverty will be reduced -- including at the local level -- and tracking and reporting regularly and publicly
on each project‟s outcomes, development impacts, and any necessary mitigation efforts in order to ensure
a basic level of accountability.
3. Establish clear mechanisms for making the policies more enforceable and accountable and reject
self-monitoring by corporations as proposed throughout the proposed Performance Standards. IFC must
take responsibility for meaningful supervision and project monitoring in a publicly transparent and
accountable manner, which would include, at a minimum, the public release of all Action Plans.

4. Ensure that information is disclosed in appropriate languages in a timely and predictable way
throughout the project cycle. This includes defining clear rules for the early release of all action
plans, social and environmental assessments, monitoring and evaluation reports, as well as procedural
guarantee that reflect a genuine commitment to the presumption of disclosure. The IFC must also require
the public disclosure of all host government agreements and similar contracts, as well as increase the
transparency of revenues from IFC-supported investments.

5. Screen all companies for their past performance on environmental, social and human rights issues.
The IFC should only lend to clients who are fully committed to sustainable development and safeguarding
the environment and internationally agreed human rights of local communities, workers and vulnerable
groups. We emphasize one of the main conclusions of the CAO‟s internal review of the IFC‟s safeguard
policies, which stated that the private sector client‟s commitment to environment and social protections is
the main determinant of whether or not the company will comply with IFC‟s policies.

6. Uphold and ensure compliance with international human rights, labor and environmental laws,
conventions, and norms. The Performance Standards should make reference to relevant international
laws and standards and ensure that projects are designed and implemented in accordance with the client‟s
and host countries‟ applicable international commitments. IFC has an obligation to ensure that its clients
abide by relevant international laws and norms and therefore, as recommended by the CAO, must
“systematically consider risks to human rights at the project level, take appropriate [and effective] steps to
mitigate them and provide clearer guidance to clients on both these aspects. [T]hese aspects should be
reported on at the project level.” Such assessments and reports must be undertaken by reputable and
independent third parties and not by the client itself and be a pre-condition of IFC support for the project.
Project affected persons, communities and indigenous peoples have the right to participate in project
assessments, reporting and human rights audits.

7. Ensure respect for indigenous peoples’ internationally guaranteed rights, including their rights of
ownership over lands and resources traditionally owned or otherwise occupied and used, and only support
projects that have the free, prior and informed consent of indigenous peoples arrived at through their
customary decision-making processes and institutions subsequent to meaningful and good faith
consultation and their informed and effective participation commencing at the earliest stages of project
design, and agreement on benefits. These customary decision-making processes constitute culturally
appropriate and collective decision-making, which enhances indigenous peoples‟ self-development. All
agreements between relevant parties will be reflected in the loan covenants and be made publicly
available. We strongly reject the cynical manipulation of free, prior and informed consent as „free, prior
and informed consultation leading to broad community support‟ and insist that the IFC and others not use
this language.

8. Ensure that conditions are in place for meaningful and respectful engagement with affected
communities (free, prior informed consent). In addition, the IFC should ensure a process whereby, after
having access to all relevant information in an appropriate language and form, local communities identify
their development priorities and the benefits and results that they want to achieve, rather than allowing the
company or others to determine the benefits they will provide. One of the IFC's core responsibilities must
be to evaluate community acceptance, negotiated settlements, and meaningful participation and not leave
this to the private sector clients. This requires ongoing supervision and monitoring to ensure that any
agreements entered into between communities and the client are respected over time. All projects that
involve the displacement of local people must be subject to their consent, and must result in an
improvement of their standards of living and quality of life and include full restoration of their livelihoods
and resource base.

9. Include a self-selected community-based monitoring approach for projects with significant social and
environmental impacts to improve oversight and accountability of these projects. One key component will
be strengthening the community‟s capacity to monitor projects by ensuring that project funds are made
available for this purpose and are independent of company or government influence. Furthermore, the
community should have influence regarding the terms of reference of the monitoring methodology used.
All community monitors should be informed of the requirements of the IFC policies and Performance
Standards, and should be informed about the processes of accountability at the IFC in a language and
manner that is appropriate for them, so that they have a full understanding of their rights and potential
remedies. Outcomes and recommendations of monitoring should be made public and affect the future
direction of the project.

10. Commit to measuring, disclosing and reducing the harmful impacts of climate change in the
developing world by requiring a reduction in overall emissions from IFC investments at the project level.
Work with companies to reduce emissions and operate more efficiently and report fully on the direct and
indirect emissions that result from IFC portfolio investments, including financial intermediaries.
Furthermore, the IFC should more aggressively shift its portfolio towards renewable energy lending.

11. Define IFC’s ‘no-go circumstances’ in the overall policy by including the current Exclusion List and
expanding it to include, at a minimum,

       IUCN I-IV protected areas and World Heritage sites for all industrial activities and other areas
        that are deemed to be of high conservation value, as defined through a multi-stakeholder process
        for all Category A projects;
       Certain practices that are particularly destructive, such as riverine and submarine tailings disposal
        of mine waste;
       Clarifying social, cultural and environmental „no-go circumstances‟ and the criteria used.

Endorsed by:

Kate Walsh                                                 Dr Mariann Lloyd-Smith
AID/WATCH, Australia                                       National Toxics Network, Australia

Justin Sherrard                                            John Seed
Cambiar Pty Limited, Australia                             Rainforest Information Centre, Australia

Binnie O'Dwyer                                             Elfriede Schachner
Friends of the Earth, Australia                            AGEZ - Arbeitsgemeinschaft
                                                           Entwicklungszusammenarbeit (Coalitionof 29
Rowland Benjamin                                           Development NGOs), Austria
Information for Action, Australia
                                                           Nonno Breuss
Stewart Mills                                              ECA-Watch Austria and ATTAC, Austria
Jubilee Australia, Australia

Techa Beaumont
Mineral Policy Institute, Australia
Heinz Hödl                                      Esther Neuhaus
Koordinierungsstelle der Österreichischen       Brazilian Forum of NGOs and Social
Bischofskonferenz iinternationale Entwicklung   Movements for Environment and Development,
und Mission (KOO), Austria                      (Representing over 1000 Groups)
Mayis Gulaliyev
Center for Civic Initiatives, Azerbaijan        Alcides Faria
                                                Ecoa - Ecology and Action, Brazil
Galina Kozlova
Ecograph, Azerbaijan                            Francisco Milanez
                                                Ecofund, Brazil
Telman Zeynalov
Ecological Department NGO FORUM,                Maurício Galinkin
Azerbaijan                                      Fundação CEBRAC, Brazil

Telman Zeynalov                                 Renato Cunha
National Center of Enviromental Forecasting,    Gambá, Brazil
                                                Sérgio Guimarães
Zakir Kibria                                    Instituto Centro de Vida, Brazil
BanglaPraxis, Bangladesh
                                                Donald Sawyer
Arup Rahee                                      Instituto Sociedade, População e Naturaza,
LOKOJ, Bangladesh                               Brazil

Ashraf-ul-Alam Tutu                             Marcus Faro
Coastal Development Partnership (CDP),          Rede Brasil sobre Bancos Multilaterais, Brazil
                                                Bestey Neal
Ann De Jonghe                                   Rede Mata Atlântica, Brazil
Broederlijk Delen, Belgium
                                                Alessandro Menezes
Judith Neyer                                    Rede Pantanal, Brazil
FERN, Belgium
                                                Petko Kovatchev
Johan Bosman                                    Center for Environmental Information and
KWIA, Flemish Support Group for Indigenous      Education, Bulgaria
Peoples, Belgium
                                                Ivailo Hlebarov
Jan Cappelle                                    Za Zemiata, Bulgaria
Proyecto Gato, Belgium
                                                Issaka Herman
Smiler Morosi Paz                               TRAORE, Burkina Faso
Confederacion Nacional de Naciones Indegenas
Orginiarias de Bolivia (CONNIOB), Bolivia       Seak Sophat
                                                Royal University of Phnom Penh, Cambodia
Flávia Barros
INCLUIR - Instituto de Pesquisa e Assessoria    Florence Ntassi
sobre Desenvolvimento e Globalização, Brasil    Center for Environment and Development
                                                (CED), Cameroon
Roberto Smeraldi
Amigos da Terra - Amazônia Brasileira, Brazil   Akong Charles Ndika
                                                Global Village Cameroon, Cameroon
Ndoumbe Nkotto Honoré                           Philippe Quirion
FOCARFE, Cameroon                               Climate Action Network, France

Anil Naidoo                                     Sebastien Fourmy
Blue Planet Project/The Council of Canadians,   French IFI network, France
                                                Sébastien Godinot
Robert Walker                                   Friends of the Earth, France
Ethical Funds, Canada
                                                Xavier Bouchet
Graham Saul                                     Gabas Nature et Patrimoine, France
Friends of the Earth, Canada
                                                Yannick Jadot
Michael Bassett                                 Greenpeace, France
Halifax Initiative Coalition, Canada
                                                Guy Leger
Jamie Kneen                                     MNLE, France
Mining Watch, Canada
                                                Aurore Lebouchard
Dermot Foley                                    Mouvement International de la Reconcilation
Real Assets Investment Management Inc.,         (MIR France), France
                                                Monique Derue
Derek MacCuish                                  Peuples Solidaires, France
The Social Justice Committee, Canada
                                                Annie Girard
Isaac Rojas                                     Réseau Foi et Justice Afrique-Europe, France
COECOCeiba - FoE Costa Rica, Costa Rica
                                                Bernard Salamand
Petr Hlobil                                     Ritimo, France
Centre for Transport and Energy (CDE), Czech
Republic                                        Danielle Toure Roberget
                                                Eau Vive, France
Pavel Pribyl
Hnuti Duha, Czech Republic                      Gerard Borvon
                                                S-EAU-S, France
Hannah Ellis
Friends of the Earth, England, Wales &          Michel Roy
Northern Ireland                                Secours Catholique / Caritas, France

Peep Mardiste                                   Sharon Courtoux
Estonian Green Movement, Estonia                Survie SFI, France

David Eloy                                      Regis Renard
AITEC, France                                   Terre des Hommes, France

Jean-Luc Touly                                  Remy Martin
Association pour un Contrat Mondial de l'Eau,   Uminate (network of 150 local NGOs), France
                                                Kakha Nadiradze
Alex Nikichuk                                   Association for Farmers Rights Defense
ATTAC France Water Group, France                (AFRD), Georgia
Nino Gujaraidze                                 Joe Athialy
Green Alternative Association, Georgia          The People's Movement, India

Lali Kobiashvili                                Meda Gurudutt Prasad
The Association of Childrens` and Patients‟     CADME/ACTION, India
Rights Protection Asklepsius, Georgia
                                                Souparna Lahiri
Lasha Chkhartishvili                            Delhi Forum, India
Union of Environmental Protection and Animal
Rights - "LOBO", Georgia                        Mukta Srivastava
                                                Initiative, India
Tsovinar Nazarova
People's Harmonious Development Society,        Medha Patkar
Georgia                                         Narmada Bachao Andolan (Save the Narmada
                                                Movement), India
Gertraud Gauer-Süß
Bremer Informationszentrum für                  Sanjay M.G.
Menschenrechte und Entwicklung, Germany         National Alliance of People's Movements, India

Ulrich H. Gundert                               Prajnalankar Bhikkhu
Brot für die Welt, Germany                      Peace Campaign Group (PCG), India

Roger Meyer                                     Himanshu Thakkar
Eirene Deutscher Zeig E.V., Germany             South Asia Network on Dams, Rivers & People
                                                (SANDRP), India
Ulrich Mueller
FoodFirst Information & Action Network,         Binny Buchori
Germany                                         INFID (International NGO Forum on Indonesian
                                                Development), Indonesia
Jürgen Marquardt
Lernen – Helfen – Leben, Germany                Heine Nababan
                                                People's Coalition for the Rights to Water,
Reinhard Behrend                                Indonesia
Rettet den Regenwald, Germany
                                                Longgena Ginting
Knud Voecking                                   WALHI, Indonesia
Urgewald, Germany
                                                Manana Kochladze
Andrea Plöger                                   CEE Bankwatch Network, International
W E E D - World Economy, Ecology &
Development, Germany                            Kate Watters
                                                Crude Accountability, International
Daniel Owusu-Koranteng
Wassa Association of Communities Affected by    Janneke Bruil
Mining, Ghana                                   Friends of the Earth, International

Yannick Etienne                                 Daniel Moss
Batay Ouvriye, Haiti                            Grassroots International, International

Ákos Éger                                       Bernice Romero
National Society of Conservationists, Hungary   Oxfam International, International
Johan Frijns                                     Kalia Moldogazieva
BankTrack, International                         Human Development Center "Tree of Life",
                                                 Kyrgyz Republic
Jaroslava Colajacomo
Campagna per la riforma della Banca Mondiale     Natalia Ablova
(CRBM), Italy                                    Bureau on Human Rights and Rule of Law,
Laura Radiconcini
Friends of the Earth, Italy                      Tolekan Ismailova
                                                 PA "Civil Society Against Corruption",
Francesco Ferrante                               Kyrgyzstan
Legambiente, Italy
                                                 Saulius Piksrys
Gianfranco Bologna                               Atgaja, Lithuania
WWF, Italy
                                                 Ana Colovic
Yoshihito Miyakoshi                              Eco-sense, Macedonia
A SEED, Japan
                                                 Balan Palanisamy
Naomi Kanzaki                                    Penang Inshore Fishermen Welfare Association
Friends of the Earth, Japan                      (PIFWA), Malaysia

Keiko Kusuhara                                   Roy Laifungbam
Fukuoka NGO forum on ADB, Japan                  South Asian Solidarity for Rivers and People
                                                 (SARP), Nepal
Yuki Tanabe
Japan Center for a Sustainable Environment and   Filka Sekulova
Society (JACSES), Japan                          A SEED Europe, Netherlands

Setsuko Kudo                                     Henneke Brink
Jubilee Kansai Net-Work, Japan                   Both ENDS, Netherlands

FUKUDA Kenji                                     Eloho Ogberagha
Mekong Watch, Japan                              Agency for Health and Environmental Projects,
Semen Svitelman
Green Salvation, Kazakhstan                      Innih Archibong
                                                 Liberty Now, Nigeria
Andrey Andreyev
NGO Legal Initiative, Kazakhstan                 Andrew Preston
                                                 Association for International Water and Forest
Valery Uleev                                     Studies, Norway
Jalal-Abad Regional Human Rights
Organization "Justice" ("Spravedlivost"),        Lars Løvold
Kyghyzstan                                       Rainforest Foundation, Norway

Ramazan Dyryldaev                                Naeem Iqbal
Committee for Human Rights, Kyrgyz Republic      Pakistan Network for Rivers Dams and People,
Igor Hadjamberdiev,
For Civil Society NGO, Kyrgyz Republic           Shaukat Omari
                                                 Transparency International, Pakistan
Lester Seri                                      Ivan Blokov
Conservation Melanesia Inc., Papua New           Greenpeace, Russia
                                                 Dr. Evgeny V. Vilkov
Jorge Bejar Apaza                                Russian Academy of Sciences, of Daghestan
Asociación Civil LABOR, Perú                     Scientific Centre, Russia

Miguel Palacín Quispe                            Dmitriy Lisitsyn,
CONACAMI (National Confederation of              Sakhalin Environment Watch, Russia
Peruvian Communities Affected by Mining),
Perú                                             Alexander Arbachakov
                                                 Taiga Research and Protection Agency, Russia
Oscar Díaz Barbosa & Zaira Carbajal Jara
Instituto Ambientalista Natura, Perú             Kalinina Natalia V.
                                                 The Organization Amur Ecological Club, Russia
Joan Carling
Cordillera Peoples Alliance, Philippines         Jennie Sutton
                                                 The Regional NGO Baikal Environmental Wave
Monica Wilson                                    of the Russian Federation, Russia
GAIA (Global Alliance for Incinerator
Alternatives), Philippines and USA               Peter Mihok
                                                 Center for Environmental Public Advocacy,
Joanna Bulawa                                    Slovakia
Green Federation Gaja, Poland
                                                 Wally Menne
Andrzej Gula                                     Timberwatch Coalition, South Africa
Institute for Environmental Tax Reform, Poland
                                                 Mario Carreño Fuego
Anna Roggenbuck                                  Proyecto de Cooperación y Ayuda al Pueblo
Polish Green Network, Poland                     Ticuna, Spain

Renato Miguel Ascenso Roldao                     Mailer Mattié
Euronatura – Centre for Environmental Law and    Selva.org, Spain
Sustainable Development/ ECA Iberia, Portugal
                                                 Hemantha Withanage
Sergey Fedorov                                   Center for Environmental Justice, Sri Lanka
Arkhangelsk Association of Ecological
Organizations, Russia                            Deshamanya Dr. Ponna Wignaraja
                                                 South Asian Perspectives Network Association,
Fatima Kobzhasarova                              Sri Lanka
Chelyabinsk City Public Movement of Women
"Fatiha", Russia                                 Christine Eberlein
                                                 Berne Declaration, Switzerland
Druzina Movement, Russia                         Bruno Gurtner
                                                 Swiss Coalition of Development Organizations,
Inga Zinovieva                                   Switzerland
Ecological Environmet Center Dauria, Russia
                                                 Jim Enright
Andrey Laletin                                   Mangrove Action Project (MAP), Thailand
Friends of the Siberian Forests, Russia
                                                 Antonina Galkina
MC Joint Action, Ukraine
Yury Urbansky                                    Tom Athanasiou
National Ecological Center of Ukraine, Ukraine   EcoEquity, USA

Jeff Powell                                      Bruce Rich
Bretton Woods Project, United Kingdom            Environmental Defense, USA

Tom Griffiths                                    David Waskow
Forest Peoples Programme, United Kingdom         Friends of the Earth, USA

Richard Harkinson                                Elaine Zuckerman
Minewatch, United Kingdom                        Gender Action, USA

Nicholas Hildyard                                Paula Palmer
The Corner House, United Kingdom                 Global Response, USA

Roberto Bissio                                   Rev. David Schilling and Sister Patricia Wolf
Third World Institute, Uruguay                   Interfaith Center on Corporate Responsibility,
Soren Ambrose
50 Years Is Enough: U.S. Network for Global      Dana Clark
Economic Justice, USA                            International Accountability Project, USA

Dave Batker                                      Bama Athreya
Asia Pacific Environmental Exchange, USA         International Labor Rights Fund, USA

Dick Kamp                                        Peter Bosshard
Border Ecology Project, USA                      International Rivers Network, USA

Lauren Compere                                   Doris Gormley
Boston Common Asset Management, LLC,             Jesuit Conference, USA
                                                 Séamus P. Finn OMI
Susan Vickers                                    Justice/Peace & Integrity of Creation, USA
Catholic Healthcare West, USA
                                                 Andrew Brengle
Julie Tanner                                     KLD Research & Analytics, Inc., USA
Christian Brothers Investment Services, Inc.,
USA                                              Alfredo Quarto
                                                 Mangrove Action Project, USA
Anne Perrault
Center for International Environmental Law       Marie Dennis
(CIEL), USA                                      Maryknoll Office for Global Concerns, USA

Doug Hellinger                                   Catherine Rowan
Development Gap, USA                             Maryknoll Sisters, USA

Adam Kanzer                                      Mark A. Regier
Domini Social Investments LLC, USA               Mennonite Mutual Aid, USA

Valerie Heinonen                                 Valerie Heinonen
Dominican Sisters of Hope, USA                   Mercy Investment Program, USA
                                                 Caucasus Environmental NGO Network
Barbara Bramble                                  (CENN)
National Wildlife Federation, USA

S. Jacob Scherr
Natural Resources Defense Council, USA

Bruce Herbert
Newground Social Investment, USA

Doug Norlen
Pacific Environment, USA

Marcia Ishii-Eiteman, PhD
Pesticide Action Network North America

Mike Brune
Rainforest Action Network, USA

Tim Keating
Rainforest Relief, USA

Valerie Heinonen
Sisters of Mercy Regional Community of
Detroit Ursuline,
Sisters of Tildonk-U.S. Province, USA

Steve Lippman
Trillium Asset Management, USA

Rev. Douglas B. Hunt
United Church of Christ Network for
Environmental and Economic Responsibility,

Aniruddha Vahadilla, USA

Bruce Jenkins
Bank Information Center, USA

Kevin Danaher
Global Exchange, USA

Nora. M. Nash
Corporate Social Responsibility Sisters of St
Francis of Philadelphia, USA

Domuladjanov Ibragijon
“For Ecologically Clean Ferghana” Association,