Both ENDS
Both ENDS has been asked by FMO to comment on its draft investment approach to responsibly managed forest plantations. To follow are a number of observations and recommendations, partially informed by Both ENDS long legacy of working in the forest & land arena, in dialogue with international donors, philanthropic foundations, companies, certification bodies and notably with forest dependent communities and other land users.
Both ENDS partner IFI Synergy has filed a complaint to the World Bank on behalf of local inhabitants about the Nachtigal dam in Cameroon. The dam is causing considerable problems for local communities and local people feel that the compensation they receive is inadequate. They also feel that they were insufficiently informed and consulted before construction of the dam started.
In a new Position Statement on Financial Intermediary (FI) Lending, Dutch development bank FMO argues for limited responsibility over the outcomes investments that are channeled through commercial banks, investment funds, and other financial intermediaries, representing by far the bigger sector of its portfolio. In doing so, FMO is undermining its development mission, including the protection of human rights and addressing the climate crisis. FMO intends to delegate these key responsibilities to its FI clients only, falling short of best practices of peer financial institutions. In a joint submission prepared by Both ENDS, Oxfam Novib, Recourse and SOMO, we argue that FMO can do much more to ensure the protection of human rights, the environment, and to measure the development impact of its indirect investments.
As we celebrate both the 30th anniversary of the UN Declaration on the Right to Development (December 4th) and Human Rights Day (December 10th), Both ENDS joins with communities and civil society groups around the world to call on development finance institutions, governments, and businesses to take 3 steps to stand up for Human Rights in development.
This letter by Both ENDS to the African Development Bank is a comment written in reaction to a draft version published by the Bank of its Environmental and Social Policy as part of a formal public consultation held by the Bank. This comment was sent to the bank along a joint submission letter with other CSOs, and specifically responds to the overarching Policy.
The bank's flexible requirements for clients and national standards for risky projects dilute safeguards. Project approval should be predicated on specific and binding targets for compliance and reflect input from communities involved.
Together with 29 other CSO's, we've submitted our comments and recommendations in the Public Consultation on the AfDB Integrated Safeguards System. These include that the Bank should prioritize community-led development and human rights-based approaches; protect natural resources and tackles environmental and climate crises; raise the bar on access to information, transparency and accountability; facilitate participatory processes in policies, programmes and projects; and end inequality, poverty, and the cutback and privatization of vital services.
Both ENDS letter to the World Bank on the Environmental and Social Safeguards policies review. The World Bank safeguards review is part of a reorganization that aims at making lending cost-effective with less rules in place, which likely entails an increase in the number of problem projects. The reorganization aims at making lending
more cost-effective, forms in place. Safeguards policies are of crucial importance for project affected people to hold banks to account. However, Environmental and Social Frameworks (ESF) nowadays replace safeguards at banks. The ESF model leads to a reduction of a Bank's direct and mandatory role in overview, including due diligence, monitoring, and evaluation, of Bank funded activities and investments, along with a shift towards a greater reliance on client self-assessment and self-reporting. Our main ask is a return to binding, rules-based safeguards policies at banks.
6 civil society organizations, including Both ENDS have submitted a gender comment on the newly proposed EIB Environmental and Social Framework. The EIB Environmental and Social Standards has to be updated to ensure that due attention to gender specific impacts, risks and related mitigation strategies is integrated in the policy and each standard, as well the assessment needs to specifically address the needs and problems of all genders. A lot of improvements can be made in the integration of gender aspects in policy and standards, in order to prevent violation of the rights of women and girls during project implementation, and tools (widely used by other organisations) and or commitments for their development should be included (inclusive consultations, Gender assessments and analyses, gender impact assessment, Legal Assessment Tool (LAT) for gender-equitable land tenure, gender responsive tools for prevention of violence.
