25 civil society organisations, including Both ENDS have submitted a comment on the overarching policy of the newly proposed Environmental and Social Framework of the EIB Group. The EIB has to undertake environmental, climate, social and human rights assessment and appraisal of proposed projects to inform the decision of financing and must not rely on a clients' self-assessment and reporting (solely). The Policy needs to state clearly what the due diligence, monitoring and reporting responisibilities for the EIB are, in particular regarding human rights and contractual clauses with clients should enshrine the standards in all EIB operations, enabling for suspension of contracts if the standards are not implemented.
Both ENDS co-wrote a Joint CSO Submission on the Draft Revised Version of the EIB Transparency Policy to the EIB. The transparency policy does not adequately reflect key international standards and principles regarding transparency, as set out in the Global Transparency Initiative's Transparency Charter for International Financial Institutions.
The policy should meet the nine key principles as set out in the Global Transparency Initiative's Transparency Charter for International Financial Institutions, namely: 1) the right of access,; 2) automatic disclosure,; 3) access to decision-making; 4) the right to request information; 5) limited exceptions; 6) appeals; 7) whistleblower protection; 8) the promotion of freedom of information; and 9) regular review.