3 February 2025
Via Electronic Mail
Ramanie Kunanayagam
Chair, Compliance Review Panel Asian Development Bank
6 ADB Avenue, Mandaluyong City 1550 Metro Manila, Philippines
Dear Ms. Kunanayagam,
Congratulations on your appointment to the critical post of the Chair, Compliance Review Panel (“CRP”) for the Accountability Mechanism of the Asian Development Bank. We want to take this opportunity to introduce ourselves and welcome you to your new role.
NGO Forum on ADB is an Asian-led network of civil society organizations that strives to make the Asian Development Bank (ADB) and the Asian Infrastructure Investment Bank (AIIB) responsible and accountable for the impacts of their projects and policies. With over three decades of experience in monitoring ADB, NGO Forum advocates for development finance to respect the rights of its intended beneficiaries and be accountable to communities harmed by development projects. We have worked alongside communities to support their engagement with accountability processes at the ADB. Over the past years, we have been critical in advocating for a robust, rights-based, and just safeguards policy, and for an independent, accessible, and effective Accountability Mechanism. In the upcoming year, we plan to actively engage in the review of the Accountability Mechanism Policy 2012 (“AM Policy”) to ensure it is in line with international good practice [1].
We look forward to having someone with your distinguished record as an accountability expert appointed as Chair, CRP. The CRP provides independent oversight over ADB’s compliance with its own operational policies and procedures and an avenue for communities negatively impacted by ADB’s finance to raise grievances and receive remedy. In recent years, the CRP has faced many challenges—encroachments on its independence from management, accessibility roadblocks, and a remedy gap for communities. In our experience, the Chair plays a vital role in ensuring that the rights of communities are duly protected at every stage of the compliance review process, including during the investigation, formulation of the remedial action plan, and monitoring, and in ensuring that the CRP is able to withstand pressure from other interests within the Bank.
As you start your tenure, we are actively involved in the AM Policy review process and are advocating for crucial changes to the CRP’s mandate and function, such as the ability to initiate investigations without Board authorization.
the ability to make recommendations to address non-compliance, and an explicit recognition of the duty to provide remedy to communities that have suffered harm. The review process also raises crucial questions around the structure of the Accountability Mechanism (including the independence of the problem-solving function) and the CRP’s ability to self-initiate investigations or investigate instances of likely or potential harm. We count on your expertise and leadership during the review process to ensure the new AM Policy respects international good practice and sets new standards on these issues. In our respective capacities, we offer our expertise and support based on our work seeking justice alongside impacted communities and strengthening accountability mechanism policies across development banks.
Over the past years, CSOs and the CRP have also built a relationship of collaboration based on trust and our common goal to support communities seeking redress from harmful impacts of ADB’s projects. We appreciated the proactive steps taken by the Accountability Mechanism to seek our insight to develop a “Guide to Approaches to Risks of Retaliation” [2] to combat against the ever-present risk of reprisal in accountability mechanism processes.
We hope that under your leadership, the CRP will continue to meaningfully consult with CSOs as an important aspect of its functioning.
We hope we can continue this dialogue further so that we may learn more of your vision regarding the CRP and the role of civil society in pursuing your priorities. We look forward to a virtual meeting with you in the near future.
Once again, a very warm congratulations on your appointment.
Respectfully,
NGO Forum on ADB
Accountability Counsel
Endorsed by:
350.org Asia
Bank Climate Advocates
Bank Information Center, USA
Bangladesh Working Group on External Debt (BWGED)
Bir Duino Kyrgyzstan
Buliisa Initiative for Rural Development Organisation
CEE Bankwatch Network
Centre for Community Mobilization and Support NGO, (CCMS, Armenia)
Centre for Research and Advocacy Manipur
Coastal Livelihood and Environmental Action Network (CLEAN)
Community Resource Centre
Defenders in Development Campaign
Fundación CAUCE: Cultura Ambiental - Causa Ecologista (Argentina)
Gender Action
GongGam Human Rights Law Foundation
Green Advocates International
Green Alternative
Growthwatch
Inclusive Development International
Indigenous Women Legal Awareness Group (INWOLAG)
Initiative for Right View (IRV)
International Accountability Project
Indian Social Action Forum (INSAF)
Lumière Synergie Pour le Développement
Nash Vek Public Foundation
OT Watch Mongolia
PA "Bir Duino-Kyrgyzstan"
Pakistan Fisherfolk Forum
Peace Point Development Foundation-PPDF
Reality of Aid - Asia Pacific
Recourse
South Asia Just Transition Alliance (SAJTA)
Urgewald
Uzbek Forum for Human Rights
YGPE
1 An online independent accountability mechanism benchmark tool can be found at www.accountabilityconsole.com. Also see, Multiple Authors, Good Policy Paper: Guiding Practice from the Policies of Independent Accountability Mechanisms, 2024, available at: https://www.accountabilitycounsel.org/wp-content/uploads/good-policy-paper-2024.pdf
2 Guide to Approaches to Risks of Retaliation by the Asian Development Bank’s Accountability Mechanism: Processes and Activities, 2024, available at: https://www.adb.org/documents/guide-approaches-risks-retaliation-adb-am
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