·         Lifts 1991 proscription on World Bank-funded logging in old-growth tropical forests

·         No requirement of borrowers to secure forest peoples' tenurial rights

·         Inadequate safeguards for protecting the rights of forest peoples in non-forestry projects

·         No clear provisions for participation in national level policy interventions and PROFOR activities

·         does  not apply to structural adjustment and programmatic lending

·         has less secure provisions to protect customary rights

·         permits resettlement of Indigenous Peoples even if this would have ‘significant adverse impacts on their cultural survival’

·         has provisions which permit the curtailment of the traditional resource rights of indigenous peoples in legally recognised national parks and protected areas.

·         discriminatory treatment of people whose livelihoods are curtailed by protected areas

·         questionable distinction between voluntary and involuntary resettlement

·         no requirement that standards of living or livelihoods are improved

·         not commensurate with standards IDB or World Commission on Dams (especially no prior and informed consent for Indigenous Peoples)

·         first round comments by Indigenous Peoples have been substantially ignored

·         mandatory provision requiring that Borrower take special action to secure indigenous rights to land has been replaced with vague language asking Borrower to pay ‘particular attention’. Bank now offers assistance to regularise tenure only ‘upon request from the Borrower’  

·         Indigenous Peoples Plan now only required when projects are pre-judged to have adverse impacts

·         Previously required actions to address legal and institutional issues again made subject to ‘request from borrowers’

·         Does not require protection of indigenous peoples’ intellectual property rights and is inconsistent with international standards (cf. art. 8j of CBD), which requires equitable benefit sharing

·         Inconsistent with international human rights of indigenous peoples