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Mr. James Wolfensohn
Re: Seriously flawed consultation process for IFC Safeguard Policy Update We, the undersigned members of development, human rights, environmental and indigenous peoples' organisations, and concerned individuals, would like to inform you of our deep concerns about the IFC Safeguard and Disclosure Update Process which is already underway. As the IFC itself acknowledges, its proposals could become a global benchmark for international investment for both public and private financiers. While we support the intention of the IFC to update its policies, we are alarmed that the first consultation drafts (dated 12 August 2004) imply a major shift from a mandatory and compliance-based approach to a mainly discretionary approach. Such a shift would dilute the responsibilities of a public institution and undermine its accountability to affected communities. The substantial proposed revisions to the policies largely ignore the priorities and concerns expressed by rights-holders and civil society organisations in numerous previous Bank consultations on its safeguard policies. The proposals likewise disregard many key recommendations and lessons emerging from the safeguard policy review undertaken by the Compliance Advisor and Ombudsman (CAO) and the recently completed Extractive Industries Review (EIR). We believe that the IFC revision process should result in a mandatory and rights-based approach to “safeguard” and disclosure issues and better protection of people and the environment in accordance with the World Bank Group's mandate to alleviate poverty through sustainable development. However, the draft documents that have been released reveal a disturbing re-orientation of the policies towards accommodating the needs of private sector clients, with scant mention of the rights of the affected communities whose interests would be most impacted by these proposals. Given the potentially significant implications of such proposed changes, the IFC must, as a minimum, ensure that its process for engagement with civil society is undertaken in accordance with World Bank best practice and the IFC's own guidelines for good faith public consultation. At present, the process is fundamentally flawed. The timeframe will exclude and marginalise the participation of civil society groups, especially those most affected by the proposed substantial changes. The rushed schedule also seems to be driven by an internal and arbitrary desire to conclude this process by February next year. This allows only a little over four months for a proposed worldwide debate on the IFC's plans to replace the entire set of its existing Safeguards. We feel this is a grossly inadequate period to re-assess policies and standards which took years to formulate. Furthermore, documents essential for assessing the full ramifications of these policy revisions, such as the implementation guides and the IFC's revised corporate procedures, are simply not available yet. In addition, less than 30 days before the first regional consultation planned to take place in Brazil, the proposed draft documentation has still not been translated into all appropriate languages, including Portuguese. These serious flaws and shortcomings in the proposed consultation process are not acceptable and do not reflect a good faith engagement with civil society by the IFC. If our organizations are to consider participating in the IFC consultation, we believe that it is essential that the IFC takes at least the following measures:
In order to ensure transparency and informed and equitable participation we also recommend that the consultation process is revised to:
Given the fact that the first regional consultation is scheduled for the end of this month, we trust that you will take immediate steps to rectify this current process which is at present fundamentally flawed. We hope to hear a response from the Bank on its action to implement measures to ensure effective public consultation no later than 24th September 2004. Unless the above minimum preconditions for meaningful and informed consultation are in are put in place, we do not see how we can participate in this process as we fear it will be lacking any acceptable level of credibility. Signed jointly by the following organisations and individuals: Jorge Acosta Arias Marcus Faro Carlos Zorrilla Souparna Lahiri Henry Tito Juan Amendares Elías Días Peía Edgar Gonzales Castro Nilton Desa Arroyo Ashish Fernandes Abdulai Darimani Simbiso Marasha Carlos Abanto Isaac Rojas Hemantha Withanage Etiosa Uyigue Victoria Corpuz Sandy Gauntlett Soumitra Ghosh Gautam Bandhopadhyay Nick Hildyard Laura Radiconcini Hannah Ellis Janneke Buril Sharon Courtoux Reinhard Behrend Tom Griffiths Geoff Nettleton Bruce Rich David Batker Knud Vöcking Johan Frijns Hildebrando Vélez Galeano Inez Louwagie David Waskow Manana Kochladze Petr Hlobil Pavel Pribyl Petko Kovatchev Ivailo Hlebarov Peep Mardiste Nino Dadalauri Ana Golovic Alda Ozola Linas Vainius Ania Roggenbuck Andrzej Gula Peter Mihok Yury Urbansky Donald Pols Soren Ambrose Colin Nicholas Sébastien Godinot
Magnólia Azevedo Said Kate Walsh Andrea Plöger David Corson-Knowles Jaroslava Colajocomo Asian Indigenous Women's Network, The Philippines Jeff Powell Filka Sekulova Naeem Iqbal Zakir Kibria Jan Cappelle Dana Clark Lars Hasselblad Torres Daphne Wysham Geodisio Diaz Graham Saul Jorge León T Henneke Brink Alfredo Quarto Peter Bosshard Andrey Laletin Alejandro Argumedo Paula Palmer Frances Carr Robert Napier Eric Bourgeois, Ph.D. Penny Miller Maria L. Butler Mag. Rudolf Remler Fraser Reilly-King, Renate Domnick, Coordinator Shoko Murakami Christophe Boyer John Mihevc Daniel Vogt Jamie Kneen Wenonah Hauter Rev. Douglas B. Hunt Doug Norlen Carlos Zorro Sánchez Binnie O'Dwyer Daniel Owusu-Koranteng Yuki Tanabe Rodica Perciali Sara Larrain Rodica Candea Institute for Ecology and Action Anthropology (INFOE), Germany Katie Redford Andreas Missbach, Alcides Faria Alvaro Gomez
Concha John Hocevar Ruth Rosenhek Teresa Perez Jean Koueda Koung Smitu Kothari Paul Bourke Adrian Goh Eduardo C. de Guzman Dr. Knarik Hovhannisyan Khushi Kabir Pradip Prabhu Duncan McLaren Azad Aliev Rev. David Ugolor Daniel Sergio Verzeñassi Elvira Díaz Colodrero cc: Executive Directors of the World Bank Group
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