Comments on IFC’s Consultation Drafts of the IFC Sustainability Policy and Performance Standards and Disclosure Policy (August, 2010)

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The undersigned civil society organizations believe the latest drafts of the Sustainability Policy, Performance Standards, and Disclosure Policy respond usefully to some issues raised previously by many civil society organizations, including, for example, several issues related to gender, resettlement, and climate change. Many of our most significant concerns, however, remain unaddressed, including centrally important issues related to due diligence, transparency, and accountability, and other issues related to substantive concerns.

In the following paper, we provide a description of how we believe the drafts must be revised to ensure (1) adequate identification and attention to risks; (2) strong development outcomes; (3) financial intermediary lending that meets poverty alleviation needs and does not avoid standards; (4) respect for indigenous peoples’ rights and other human rights; (5) protection of biodiversity; and (6) strong application of standards to IFC activities through advisory services.

Attention to these issues is particularly important given the new approach to standards adopted by IFC when it revised its environmental and social policies in 2006. Through adoption of the Social and Environmental Sustainability Policy (the Policy) and Performance Standards, IFC moved from providing a set of clear requirements for IFC clients to a so-called “outcomes-based” approach. Clients are given greater flexibility for determining how to address environmental and social concerns of projects; standards are more loosely defined and clients assume a greater role in determining what these standards mean in practice and how they can be met. IFC relinquished to these clients many responsibilities and obligations IFC once had.

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