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The NGO Forum on ADB is an Asian-led network of civil society organizations (CSOs), based in Asia and the Pacific region. এশিয়ান ডেভেলপমেন্ট ব্যাংক (এডিবি) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030 প্রজেক্ট মনিটরিং Latest News ADB Project Tracker Media Sign the 1M Petition WATCH Information Disclosure of Multilateral Development Banks in the New Era 6 May 2017 | Yokohama, Japan

ADB Energy Policy Countdown Letters to ADB Board Members This campaign unites local groups and allies to send coordinated, collective letters to ADB Board members as part of the ongoing Energy Policy review. By acting together, we create visible pressure on decision-makers, showing that concern for responsible energy policy is widespread and urgent. This pressure is crucial because it encourages the Board to prioritize public interest, climate action, and accountability, increasing the chances that the draft will reflect these priorities before it is finalized. Send Your Letter 1. Choose and download the letter that fits your focus Depending on your campaign focus, you can target your letter to the most relevant decision-makers at the ADB. This could be the Executive Director (ED) and Alternate Executive Director (AED) representing your country, or the ED and AED responsible for the specific project you are monitoring. Selecting the right recipients ensures that your message reaches the people with the authority to influence the policy or project, making your advocacy more effective. By Country (for Board of Directors and their alternates) Australia / Azerbaijan / Cambodia / Georgia / Hong Kong, China / Kiribati / Federated States of Micronesia / Nauru / Palau / Solomon Islands / Tuvalu Canada / Denmark / Finland / Ireland / The Netherlands / Norway / Sweden Austria / Germany / Luxembourg / Turkey / United Kingdom Armenia / Cook Islands / Fiji / Indonesia / Kyrgyz Republic / New Zealand / Niue / Samoa / Tonga Republic of Korea / Papua New Guinea / Sri Lanka / Taipei, China / Uzbekistan / Vanuatu / Vietnam Kazakhstan / Maldives / Marshall Islands / Mongolia / Pakistan / Philippines / Timor-Leste Belgium / France / Italy / Portugal / Spain / Switzerland/Israel Japan Afghanistan / Bangladesh / Bhutan / India / Lao People's Democratic Republic / Tajikistan / Turkmenistan Brunei Darussalam / Malaysia / Myanmar / Nepal / Singapore / Thailand United States People's Republic of China By Theme. You can select a letter based on the specific theme or issue you want to emphasize. Each letter is addressed to the Board of Directors, ADB, but you can choose which individual Board member(s) to send it to—whether it’s your country’s ED and AED or those responsible for a project you are monitoring. The available themes are Nuclear Energy Critical Minerals False Energy Solutions & Energy Transition Mechanisms (ETM) Strengthening Coal Prohibition Waste-to-Energy 2. Customize Your Letter. Fill out the two sections below the PDF and click Save. 3. Copy and paste the text below into your email - Dear Executive Director/Alternate Executive Director, We are writing to share our letter regarding the ongoing ADB Energy Policy review. We hope that you will take our perspectives into account as the Board considers the draft policy. Thank you for your time and attention to this critical matter. 4. Attach your PDF Letter 5. Send your letter to your intended recipient using your organization’s (or your own) official work email. Send us a short email letting us know which ADB ED or AED you want to send your letter to, and we will provide you with the correct contact address. Do not share the ADB Board of Directors’ emails publicly—unauthorized circulation may violate privacy rules. The information is intended for your personal use only to ensure your letter reaches the right decision-maker. Don't hesitate to get in touch with Denn (dennis@forum-adb.org ) or Jen (jen@forum-adb.org ), and they will give you the information. Send your letters by October 3, 2025 — when the Board will review the Draft ADB Energy Policy for approval

Explore key terms used in the Forum Network infographics on ADB energy projects. This glossary explains financing modalities, grants, loans, equity investments, and technical assistance in simple terms. Glossary of Terms in the Forum Network Infographics on ADB Energy Projects This glossary provides key terms used in the Forum Network infographics on ADB energy projects. These terms describe various financial instruments and approaches used by the Asian Development Bank (ADB) in its operations. E (Equity Investment) | Direct investment in a company or project, making ADB a shareholder to support development goals. Financing Modality | The specific method or instrument used to fund development projects and programs. Grant | Financial aid that does not need to be repaid, typically used for projects that support low-income countries, environmental sustainability, or social development. Loan | Borrowed funding that must be repaid, used to finance development projects in ADB member countries. Modality | ADB's financing or operational approach for projects, programs, or technical assistance, tailored to the needs of member countries. TA (Technical Assistance) | Support for capacity building, policy advice, and project preparation in member countries, often provided through grants or expert guidance.

সম্পদ 2025 December September June March 2024 December September [Special Edition] June March 2023 December September June March 2022 December Special Issue September June March 2021 December September June March 2020 ডিসেম্বর সেপ্টেম্বর জুন মার্চ 2019 ডিসেম্বর সেপ্টেম্বর জুন মার্চ একটি পুরানো Bankwatch সমস্যা খুঁজছেন? সচিবালয়ে [at]forum-adb.org-এ একটি কপির জন্য জিজ্ঞাসা করুন।

The NGO Forum on ADB is an Asian-led network of civil society organizations (CSOs), based in Asia and the Pacific region. প্রজেক্ট মনিটরিং Latest News Sign the 1M Petition ADB Project Tracker Media Role of Private Sector and Financial Intermediaries in ADB’s Energy Sector Investments 3 May 2018 | Manila, Philippines এশিয়ান ডেভেলপমেন্ট ব্যাংক (এডিবি) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030

The NGO Forum on ADB is an Asian-led network of civil society organizations (CSOs), based in Asia and the Pacific region. এশিয়ান ডেভেলপমেন্ট ব্যাংক (এডিবি) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030 প্রজেক্ট মনিটরিং Latest News ADB Project Tracker Media Sign the 1M Petition The Asian Development Bank’s (ADB) Public Communications Policy (PCP) guides the ADB’s external relations when it comes to transparency and in its operations. The PCP, also known as the policy on information disclosure, intends to provide greater access to project information documents and related information. It ensures participation by project-affected people in the development intervention of the ADB in their respective communities. It mandates all project-related documents to be posted on the ADB’s website. Access to project-related information by local people allows them to participate actively and effectively in decision-making processes related to the development agenda of international financial institutions such as the ADB in their respective communities which could adversely affect the environment and disrupt their living conditions. Issues with the PCP Though it has been stating that it values transparency and is committed to increasing information disclosure, the ADB has fallen short on its commitment to respecting the rights of the people’s right to information. The PCP does not expressly recognize public access to information is a right. Experiences on the ground have shown that the Bank lacks both the political will and the resources to respect this right. Documents identified by the ADB as publicly available are only accessible through its website. This has prevented poor communities from getting project-related information since the internet facility remains a luxury for them. Civil society groups believe that this manifests the pro-business bias of the Bank’s disclosure policy. The PCP also provides a long list of exceptions. Not all exceptions identify the serious harm to a clearly and narrowly defined, and broadly accepted, an interest that is sought to be avoided by non-disclosure. Below are NGO forum on ADB's submission, communication, and other documents on its campaign on a just ADB PCP - 05 Apr 2018 | Joint Submission of NGO Forum on ADB and Both ENDS Comments on the 2nd draft of the Public Communications Policy 14 Jan 2018 | NGO Forum on ADB's Summary Comments on the PCP Review 28 Nov 2017 | NGO Forum on ADB Summary Comments (meeting with PCP Review Team) 16 Jul 2017 | NGO Forum on ADB Letter to the ongoing consultations related to the Review of the Public Communications Policy (PCP) 12 Jul 2017 | Summary of questions and comments during the country consultations 26 Mar 2017 | ADB's response to Forum's submission on PCP Review 23 Jul 2017 | ADB's response to Forum's Letter to the ongoing consultations related to the review of the PCP (dated 17 July 2017) 17 Aug 2017 | Comments of NGO Forum on ADB on the draft staff instructions 30 Nov 2016 | NGO Forum on ADB Submission on the Draft Public Communications Policy of the Asian Development Bank 10 May 2016 | Public Communications Policy Review 04 May 2011 | NGOs warn ‘safety valve’ may impede ADB’s small success in transparency 13 Jan 2011 | ADB Must Clinch the Opportunity for Bolder PCP Reforms 22 Sep 2010 | Letter to PCP Review Team 31 Jan 2010 | Practice What You Preach 31 Jan 2009 | Statistical highlights on the Asian Development Bank’s Public Communications Policy Implementation (August 2005 to February 2009)

COVID-19 কমিউনিটি ইমার্জেন্সি ফান্ড আপডেট মোট সমর্থন প্রাপ্ত করা হয়েছে 20 আগস্ট, 2020 এর হিসাবে $9,000.00 মোট টাকা বিতরণ করা হয়েছে $4,500.00

Dive into AIIB-funded infrastructure projects across Southeast Asia with analysis from NGO Forum on ADB, focusing on project monitoring, community rights, environmental impacts, and civil society efforts to promote transparency, accountability, and just development. এশিয়ান ডেভেলপমেন্ট ব্যাংক (এডিবি) Project Monitoring Energy Campaign Project-affected People's Mechanism (PPM) AIIB Annual Meeting প্রজেক্ট মনিটরিং North Dhaka Waste to Energy Project COUNTRY: Bangladesh APPROVED FUNDING: USD100 million FINANCING TYPE: Nonsovereign The North Dhaka Waste-to-Energy Project is a 42.5 MW incineration facility situated near the Amin Bazar landfill, co-financed by the China-led Asian Infrastructure Investment Bank (AIIB) with a $100 million non-sovereign loan, and the New Development Bank (NDB), aiming to process municipal solid waste into energy through four 750-ton/day incineration lines and twin 35 MW turbo-generators connected to Savar’s grid. It is Bangladesh’s first large-scale waste-to-energy venture, categorized as AIIB Environmental & Social Category A, necessitating an ESIA, ESMP, and corrective action plan to address legacy land-acquisition issues and ongoing environmental risks. However, civil society watchdogs like CLEAN and urgewald have raised alarm over potentially higher greenhouse gas emissions (estimated at 8.3 million tons CO₂ equivalent over 25 years), toxic air pollutants (dioxins, heavy metals), and poor waste-quality control, which may undermine Bangladesh’s climate commitments. Critics also point out that weak waste collection systems could threaten plant operations, while energy tariffs set at over twice the current cost may burden taxpayers. Local environmental groups have emphasized deficiencies in public consultation, community grievance mechanisms, and transparency—citing AIIB’s historical track record of excluding affected communities during project approvals. As Bangladesh seeks sustainable waste solutions, the North Dhaka WtE project's technical ambitions must be balanced with stronger social and environmental accountability to ensure it genuinely serves both urban sanitation and climate-resilient development. Read the AIIB Observer Volume 3 Balakot Hydropower Development Project COUNTRY: Pakistan APPROVED FUNDING: USD250 million FINANCING TYPE: Sovereign The Balakot Hydropower Project in Pakistan is a 300 MW run-of-river initiative on the Kunhar River, financed by the Asian Infrastructure Investment Bank (AIIB) with a $250 million sovereign loan alongside a $300 million loan from the Asian Development Bank (ADB), intended to boost renewable energy generation (1143 GWh annually) and local employment. Despite its clean energy aims, the project has drawn widespread local backlash: residents and local councils are protesting ongoing land acquisition practices, demanding that affected families receive fair compensation, employment opportunities, and respect for ancestral sites—threatening to block major roads in response. Authorities have reportedly demolished structures and deployed police to protect Chinese engineers and workers amid community tensions. The Khyber Pakhtunkhwa government has also issued delay notices to contractors due to slow progress. Critics contend that although AIIB and ADB classify the project as environmentally sound under their frameworks, on-ground realities suggest weak community engagement, inadequate grievance redressal, and contested livelihood impacts. As such, Balakot offers a cautionary tale: major hydropower projects financed by global banks must pair technical and environmental standards with meaningful local accountability to avoid marginalizing host communities. Read the factsheet . Bangalore Metro Rail Project - Line R6 COUNTRY: India APPROVED FUNDING: USD335 million FINANCING TYPE: Sovereign The Bengaluru Metro’s ORR–Airport Line (Phases 2A and 2B), stretching 58.19 km from Central Silk Board to Kempegowda International Airport via KR Puram, is a transformative infrastructure project aimed at easing urban congestion and improving airport connectivity. Funded by a mix of public and external sources—including the Asian Development Bank (ADB), Japan International Cooperation Agency (JICA), and controversially, the China-led Asian Infrastructure Investment Bank (AIIB)—the project has drawn scrutiny from civil society organizations like Growthwatch, which have raised concerns over AIIB’s opaque financing practices and lack of strong accountability safeguards. While ADB has provided a $500 million loan and a $2 million grant to support inclusive, transit-oriented development, and JICA has offered ₹3,717 crore, AIIB’s growing footprint in Indian infrastructure is criticized for prioritizing geopolitical interests over local participation and environmental transparency. Construction began in 2021, with official targets set for completion by 2026, though delays—especially in Phase 2B—remain a concern. Growthwatch has also flagged issues with land acquisition, labor conditions, and the need for greater community consultation. Despite these challenges, the metro line is expected to benefit over 1.6 million daily commuters and reduce dependence on road transport. However, as Bengaluru’s transport infrastructure grows, the role of financial institutions like AIIB must be critically examined to ensure democratic oversight, equity, and long-term sustainability in urban development. Read - Growthwatch Letter to AIIB Derailed by the Accountability Ciap The Students of the Technical Training Centre for the Deaf (TTCD) in Bangalore, India Impact assessment of Bangalore Metro Rail Project (Reach 6) on vulnerable communities at the Cantonment Metro station BMRP & TTCD Narrative Bangladesh Bhola IPP COUNTRY: Bangladesh APPROVED FUNDING: USD60 million FINANCING TYPE: Nonsovereign The Bhola Independent Power Producer (IPP) project in Bangladesh is a 220 MW combined-cycle gas-fired power plant developed on Bhola Island by Nutan Bidyut (a subsidiary of Shapoorji Pallonji) under a Build-Own-Operate (BOO) model to address the country’s chronic power shortages. Co-financed by the Asian Infrastructure Investment Bank (AIIB)—which approved a $60 million non-sovereign loan in 2018—alongside the Islamic Development Bank and local financiers, the project was expected to generate over 1.3 TWh of electricity annually and began commercial operations in late 2019. While AIIB classified the project as Category B, implying limited environmental and social risks, and adopted frameworks for resettlement and stakeholder consultation, civil society organizations have strongly contested this assessment. In particular, CLEAN (Coastal Livelihood and Environmental Action Network), working with BWGED and NGO Forum on ADB, has played a central role in documenting serious harms caused by the project—including coerced land acquisition, destruction of farmland, waterlogging, river siltation, loss of grazing lands, and the absence of meaningful consultation or grievance redress mechanisms. In 2022, CLEAN co-filed the first formal complaint to AIIB’s Project-Affected People’s Mechanism, directly challenging the bank’s risk classification and safeguard enforcement. These findings have been echoed by international media, including Climate Home News, which criticized AIIB’s continued investment in fossil gas projects like Bhola IPP while sidelining renewable alternatives. Beyond research, CLEAN has also mobilized civil society campaigns and public actions urging AIIB to stop fossil fuel financing and adopt community-driven, sustainable energy models. Critics argue that the Bhola IPP reflects deeper structural issues in AIIB’s development approach—namely, opaque financing, weak local accountability, and inadequate environmental and social protections—particularly in contexts where civic space is limited. As such, the Bhola case serves as a warning of how large-scale, fossil-intensive energy infrastructure can disproportionately burden marginalized communities, underscoring the urgent need for transparent, inclusive, and rights-based alternatives in global energy investment. Read: Lessons learned: Filing Bhola IPP complaint in AIIB’s project affected people’s mechanism Unique Meghnaghat IPP COUNTRY: Bangladesh APPROVED FUNDING: USD110 million FINANCING TYPE: Nonsovereign The Unique Meghnaghat Power Plant in Bangladesh is a 584 MW combined-cycle gas-fired facility located along the Meghna River near Narayanganj, developed to strengthen the country’s electricity supply. While framed as a modern and “transition-ready” energy project—with features like hydrogen capability—it has faced criticism from civil society groups due to its environmental and social impacts. The project involved the acquisition of more land than officially reported, including agricultural fields and riverside areas crucial to local fishing communities. Many affected families reportedly received compensation far below market value, and the construction has led to issues like sand deposition on farmland, blocked grazing routes, and restricted river access. Although supported by international lenders under the banner of clean and reliable energy, the project has raised serious concerns about long-term fossil fuel dependency and the marginalization of local voices. Critics argue that the plant represents a continuation of top-down energy planning that prioritizes investment returns over community well-being and ecological sustainability. Read: The Meghnaghat Power Plant: A Looming Burden on Bangladesh

Track civil society engagement and critical perspectives around the AIIB Annual Meeting, with insights from NGO Forum on ADB highlighting concerns over fossil fuel financing, lack of accountability, and the need for inclusive, rights-based development in AIIB’s operations. এশিয়ান ডেভেলপমেন্ট ব্যাংক (এডিবি) Project Monitoring Energy Campaign Project-affected People's Mechanism (PPM) AIIB Annual Meeting প্রজেক্ট মনিটরিং Civil society engagement with the AIIB Annual Meetings has remained limited, fragmented, and largely symbolic—despite the bank’s public commitment to transparency and inclusive dialogue. While AIIB has opened some space for civil society to attend side events and submit questions, these forums often lack genuine responsiveness or avenues for influence. NGO Forum on ADB network have mobilized parallel events and issued joint statements to challenge AIIB’s financing of fossil fuel infrastructure, waste-to-energy incinerators, and large hydropower projects that frequently ignore the rights and voices of affected communities. The AIIB Annual Meetings are often criticized for prioritizing image management over accountability, with little space for grassroots concerns to shape policy or project design. Civil society continues to call for institutional reforms that would allow for more meaningful engagement, better access to project data, and stronger mechanisms for communities to be heard. Without these changes, AIIB’s Annual Meetings risk becoming performative exercises that fail to reflect the realities on the ground. Read - Civil society engagement and issues of concern regarding meaningful participation at the AIIB Annual Meeting 2024 Boycott of AIIB Annual Meeting 2024 due to lack of meaningful civil society engagement Critical Concerns on the Occasion of AIIB's Annual Meeting 2023 Raising Critical Concerns on the Occasion of AIIB’s Annual Meeting 2022 Key issues regarding the AIIB Annual Meeting 2021 Letter Civil society reflections on AIIB's 5th annual meeting (virtual), 2020 CSO's request for a meaningful dialogue in the Annual Meeting 2019 NGO Forum on ADB Statement to the AIIB President and management 2017 Press Statement of NGO Forum on ADB on the First AIIB Annual Meeting 2016 প্রজেক্ট মনিটরিং The AIIB Observer, published by the NGO Forum on ADB, serves as a sharp-edged watchdog newsletter highlighting contested AIIB investments—such as hydropower, waste-to-energy incineration, and fossil fuel infrastructure—and demanding accountability from the bank. Its latest edition called for a boycott of the AIIB’s Annual Meeting in Uzbekistan, arguing that AIIB consistently sidelines affected communities and reduces civic dialogue to PR theater. The Observer spotlights specific projects—like forced displacement in Indonesia’s Mandalika tourism zone, continued fossil energy investments through capital markets, and the controversial Rogun Mega‑Dam—and brings to light a joint societal call from over 30 organizations to reform the AIIB’s Project‑Affected People’s Mechanism. Ultimately, the publication contends that without genuine openness, responsive grievance processes, and community empowerment, AIIB risks perpetuating environmentally destructive and socially harmful development under the guise of promoting sustainable infrastructure. Beijing 2025 Samarkand 2024 Sharm El-Sheikh 2023

Meet the team of NGO Forum on ADB, including its Executive Director and staff working on environmental justice, energy transition, communications, and development advocacy. INTERNATIONAL SECRETARIAT History Network Structure International Committee International Secretariat FAQ জেন ডেরিলো যোগাযোগের জন্য প্রোগ্রাম সমন্বয়কারী জেন 15 বছরেরও বেশি সময় ধরে বিশ্ববিদ্যালয়ের অধ্যাপক হিসাবে কাজ করেছেন। ফিলিপাইনের পলিটেকনিক ইউনিভার্সিটি, সান সেবাস্টিয়ান কলেজ-রেকোলেটস, কলেজ অফ ডিভাইন উইজডম, অ্যাডামসন ইউনিভার্সিটি, অ্যাঞ্জেলিকাম কলেজ, এবং কলেজ অফ হলি স্পিরিট হল সেই শিক্ষা প্রতিষ্ঠানগুলির মধ্যে যেগুলির সাথে তার জড়িত থাকার সুযোগ ছিল৷ উন্নয়ন কাজের সঙ্গে তার প্রথম এক্সপোজার ছিল ফিলিপাইন মিসেরিওর পার্টনারশিপ ইনক. ম্যানিলা, ফিলিপাইন ভিত্তিক। ফিলিপাইনের পলিটেকনিক ইউনিভার্সিটি থেকে ব্রডকাস্ট কমিউনিকেশনে তার ডিগ্রী আছে এবং কমিউনিকেশনে স্নাতকোত্তর ডিগ্রি আছে, সেইসাথে মিডিয়া কালচার মাস্ট্রিচ ইউনিভার্সিটি , নেদারল্যান্ডস। তিনি বর্তমানে থেকে সাংস্কৃতিক নৃবিজ্ঞান এবং উন্নয়ন স্টাডিজে স্নাতক ডিগ্রি শেষ করছেন KU Leuven, বেলজিয়াম । তার পোর্টফোলিও দেখতে ক্লিক করুন এখানে. আপনি তার কাছে পৌঁছাতে পারেন জেন [এ] forum-adb.org.

PAKISTAN BANGLADESH INDIA INDONESIA PHILIPPINES বাংলাদেশ বাংলাদেশ সূত্র: বাংলাদেশ: কোভিড-১৯ অ্যাক্টিভ রেসপন্স অ্যান্ড এক্সপেন্ডিচার সাপোর্ট প্রোগ্রাম LATEST NEWS Read the latest COVID-19 Research produced by Growthwatch, India from the Philippines and NGO Forum on ADB. Download UPDATES 22 February 2022 ADB lends record USD 4.6 bn loans to India in 2021 1 December 2021 ADB approves $1.5 B for COVID-19 vaccines in India 21 November 2021 Why is India taking out loans for covid-19 vaccines? 24 November 2021 Govt of India, Asian Development Bank sign $300 million loan 21 May 2021 ADB commits record USD 3.92 billion loan to India in 2020

The NGO Forum on ADB is an Asian-led network of civil society organizations (CSOs), based in Asia and the Pacific region. এশিয়ান ডেভেলপমেন্ট ব্যাংক (এডিবি) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030 প্রজেক্ট মনিটরিং Latest News ADB Project Tracker Media Sign the 1M Petition Civil Society Input and Recommendations on the Stakeholder Engagement Plan Transparent and meaningful consultation guided by international practice is a cornerstone of good governance and informed decision-making. It also embeds a sense of ownership into the development process. International Financial Institutions (IFIs) such as the Inter-American Development Bank (IDB), the World Bank, the International Finance Corporation (IFC), the European Bank for Reconstruction and Development (EBRD), and the Asian Infrastructure Investment Bank (AIIB) have developed frameworks to strengthen their stakeholder engagement in the recent years. Moreover, the World Bank and EBRD have developed standalone policies and requirements for what constitutes a meaningful stakeholder consultation and engagement. It is imperative that the Asian Development Bank (ADB) strengthens its overall approach to ensure stakeholder engagement is inclusive, transparent and robust. Colleagues who had attended the virtual information sharing session on April 12 and 13 of 2021 organized by the SDCC Department of the ADB and the Consultation Team argued that the webinar formatting chosen had felt disempowering and disengaging. This is because the online format did not allow for full transparency on the participant list of the meeting and the relevant questions asked during the various sessions. This inaccessibility to the participant list is of major concern to stakeholder groups such as civil society organizations (CSOs) and human rights defenders who face a significant risk of retaliation under oppressive regimes. We, as representatives of CSOs, trade unions, and communities around the world hold this review process with utmost importance and attentiveness. While the Bank’s Stakeholder Engagement Plan (SEP) presents promising reforms, we are disconcerted that the current approach outlined in the present draft has not reflected international good practice and remains amiss on a number of salient issues. Collectively, we raise these points before the process leads to an SPS with tremendous substantial and procedural problems when the current demand is to reform toward international laws, standards, and norms. In pursuit of the shared objective of reforming the safeguard system, we forward our key recommendations: Include a definition of Meaningful Consultation underpinned by duly established policy and practice. The SEP outlines that it is based on “firm principles of meaningful consultation…”(pg.3). Meaningful Consultation should not be organized in a pro forma manner to ‘check a box or to meet an internal requirement. It should be underpinned by a clear matrix that upholds the utmost importance of the Free, Prior and Informed Consent (FPIC) prerequisite criterion recognised in the United Nations (UN) Declaration on the Rights of Indigenous Peoples, and supported by genuine consideration for stakeholders’ views and concerns. We are requesting that the term ‘Meaningful Consultation’ in the SEP be asserted by a clear definition and matrix which draws on duly established policy and practice. A clear definition of Meaningful Consultation can be found in the Safeguards Policy Statement Glossary and states that it is “A process that (i) begins early in the project preparation stage and is carried out on an ongoing basis throughout the project cycle; (ii) provides timely disclosure of relevant and adequate information that is understandable and readily accessible to affected people; (iii) is undertaken in an atmosphere free of intimidation or coercion; (iv) is gender-inclusive and responsive, and tailored to the needs of disadvantaged and vulnerable groups; and (v) enables the incorporation of all relevant views of affected people and other stakeholders into decision makings, such as project design, mitigation measures, the sharing of development benefits and opportunities, and implementation issues.” This definition should underpin the Safeguards Policy Review and Update (SPRU) and the Stakeholder Engagement Plan (SEP). Outline a clear, unambiguous plan on offline mechanisms for consultation. The current SEP Draft recognizes inaccessibility to online means of communication for many stakeholders and makes an effort to mention offline mechanisms for consultation. This is not supported by a clear plan of how these stakeholders groups will be reached for consultation, nor does the SEP make clear the schedule for the offline consultations, or the countries it would take place. Good practices of meaningful consultation warrant having an inclusive space for multi-stakeholder engagement. This includes ensuring that prior information is given to the stakeholder group (community or CSOs) in a clear, time-bound manner, and in a language that is easily understandable. To modernize the policy and make sure it upholds the highest social and environmental standards, efforts must be made to consult with Project Affected Persons (PAPs) through offline mechanisms. We urge the Bank to take this into consideration and clearly outline the list of countries it aims to hold offline consultation. Due diligence must be given specifically to projects which have gone into compliance review. Avoid reliance on demand-driven consultation. Demand-driven consultation plans will prove to be problematic as various key thematic dialogues may not be held unless civil society groups themselves proactively reach out to the ADB SDCC and the Consultation Team. The first question which arises is whether the ADB SDCC will be able to conduct a comprehensive outreach on the SEP at the national and global level to ensure that thematic and remote groups across various cultures, languages, and political contexts are aware of the ‘demand driven’ stipulations? In the current context of the pandemic, this seems very unlikely. Without a prescribed list of thematic consultations announced for each country and region, the chances of getting specialized groups to organize dialogue with ADB SDCC on their own volition without compromising their exposure to risk and scrutiny will also be a deterrent for them stepping forward. We strongly recommend the removal of the ‘demand driven’ approach as it potentially passes the burden of convening the consultation solely on the stakeholder and not on the ADB SDCC, the department responsible for convening and managing this update process. There is also a need for wider outreach on direct engagements via different communication formats, including traditional media in case of offline events. Heavy reliance on online means of communication such as social media and websites to advertise for consultation risks losing the critical voices of PAPs and communities living in remote areas. We urge the Bank to make active and reasonable efforts to include traditional means of media such as newspapers and national television advertisements in their communication plan. Meaningfully engage with young people in the consultation process. Consultations with children and young people are important about their experiences, and therefore need to be set up in a child-friendly manner that promotes the rights and respect of the child in a sensitive manner. There should be age-appropriate targeting in terms of setup, information, and messaging as well as promoting participation and inclusivity. For best practices see the Save the Children Child Consultation Toolkit . Include the Private Sector Operations Department in its internal consultation process. The ADB has announced, in its Strategy 2030, an expansion of its private sector portfolio to reach one-third of total Bank operations by 2024. Private sector operations are riddled with noncompliance, transparency, and lack of information disclosure. We have witnessed the death of 6 workers in the PSOD-led project, Nam Ngiep 1, in Laos due to failures in labor safeguarding. Similarly, the Tata Mundra Coal Project led by PSOD had critically endangered marine ecosystems and displaced thousands of local fishermen in 2014. It is imperative that ADB SDCC takes a critical look at ensuring consultations between CSOs and PSOD staff and their respective borrowing clients and subcontractors in the course of this SEP and SPRU. The OHCHR Guiding Principles on Business and Human Rights should lie at the heart of this dialogue between the Bank, private sector, and CSOs. Publicize ALL consultation comments and extend the timeline for commenting to 60 days. The SEP mentions that a summary of consultation comments will be disclosed on the SPRU webpage for two weeks. In the absence of a clear matrix on how summaries are prepared, We as CSOs are concerned that this will obscure some of the salient comments and recommendations received during the consultation process. Access to full consultation comments should be made available in addition to the summary of consultation comments to ensure full transparency. We are also requesting that the timeline for commenting is extended to 60 days to make sure that relevant stakeholders groups with minimal comprehension of the English language are able to translate the documents and submit their comments. Extend the timeline for commenting on the draft W-paper and the R-paper and subsequent revisions to a period of two months/ 60 days respectively. Good practices on meaningful consultation stipulate that stakeholders should be given sufficient time to review the information across regions and countries before being asked to express their views. Meaningful inclusion of more urgent safeguards issues supported by coherent analytical studies. We welcome the broadening of the themes to include labor, climate change, and sexual abuse and harassment in the list of analytical studies as a response to the progressing international laws, standards and norms. We urge the Bank to avoid the reliance on the blanket term of ‘vulnerability’ and misuse of terminologies such as ‘crosscutting’ to assess the varying risks affecting different groups such as peoples with disabilities, sexual and gender diverse groups, and children. Due diligence must be given to: Risk of reprisals. The silencing of critical voices through reprisals and retaliations - or the fear thereof - seriously calls into question the possibilities for a consultation to be meaningful: when these critical voices are coming from the ground and would be communicating operational risks, a climate of fear puts operations at risk, too. Similar to the World Bank, the Inter-American Development Bank, and the Asian Infrastructure Investment Bank, the ADB needs to have a clear zero tolerance position against reprisals, either as part of the SEP or as a more general statement that the SEP is bound by. In order to operationalise this zero tolerance position, the SEP needs to go beyond just alluding to it in reference to PAPs. It needs to commit to (1) carrying out contextual risks assessments, for all the different contexts in which consultations will be taking place with people deemed to potentially be at risk, looking particularly at reprisal risks, (2) devising measures to mitigate risks identified and finally it needs to include a (3) reprisal response protocol that seeks to use the leverage the bank has to address any reprisal that may occur. Human rights. Despite the IED evaluation recommendation that “the modernized SPS should also clarify the safeguard components of other key ADB objectives, which have increased in importance since the SPS, such as climate risk mitigation and adaptation, disaster risk management, the needs of disabled people, human rights, and supply chains” as well as the increasing human rights challenges and risks in the region, the SEP makes no mention of addressing anything related to human rights. We recommend a dedicated analytical study as well as consultations on the safeguard components of human rights. In 2011, the UN Human Rights Council endorsed the UN Guiding Principles on Business and Human Rights as a set of guidelines for States and companies to prevent, address and remedy human rights abuses committed in business operations. In 2020, the United Nations Global Compact announced support for mandatory human rights due diligence. The same year, the IGWG developed the second draft of an international legally binding instrument to regulate, in international human rights law, the activities of transnational corporations and other business enterprises. Currently, hundreds of large businesses, associations & investors in the EU have supported mandatory human rights due diligence legislation. It demonstrates an increasing demand to address human rights in development projects, which the ADB can not ignore. Risk Categorization. The current SEP list of thematic issues for analytical studies should include an evaluation on ADBs Risk Categorization decision making and implementation practice. As per the IEDs findings the ADBs current categorization process lacks a comprehensive risk-based approach. This leads to arbitrary risk assignment. Unless Quality at Entry documentation of a project such as EIA,IEE, SIA, IPSA have gone through layers of independent checks, arbitrary risk assessment and consequent categorization will remain a structural flaw. We urge the Bank to review the Effectiveness of the 2009 Safeguard Policy Statement for an understanding of the historic and systemic flaws plaguing Risk categorisation at the project level. A need for clear distinction between financing modalities and special issues. As outlined before, MDBs such as the ADB have cited their increased focus on promoting transparency in development financing. However, decades of CSO monitoring of private sector & FI Operations by CSOs have shown a lack of transparency. The current scope and objectives of the ‘Financing modalities and special issues’ study does not clearly define what aspects of financing modalities are being assessed adequately. Project implementation in fragile and conflict affected situations (FCAS) and small island developing states (SIDS) is an important issue which should be given due consideration and therefore we urge the Bank to make a clear distinction in its engagement and analytical approach. 11. Maintain resolute consistency with Human Rights Principles. Meaningful stakeholder consultation is enshrined in the international human rights architecture and elucidated across various conventions, resolutions, and declarations. ILO Convention 169 (1989) which deals exclusively with Indigenuous Peoples states that “they shall participate in the formulation, implementation and evaluation of plans and programs… which may affect them directly.” These principles were affirmed in the UN Declaration on the Rights of Indigenous People (UNDRIP 2007) which upholds and emphasizes on the Free, Prior, and Informed Consent (FPIC) prerequisite criterion. Similar principles were also outlined for other groups including The 1989 Convention on the Rights of the Child which elucidates that “The child shall have the right to freedom of expression; this right shall include freedom to seek, receive and impart information and ideas of all kinds”. ADB should ensure that the financed projects don’t contribute to human rights abuses violations, assaults on local communities and human rights defenders, and shrinking civil society space. The Bank should incorporate in their SEP a clear strategy on Human Rights to protect communities, Indigenous Peoples, and human rights defenders, and enhance public participation. This strategy should detail how human rights risks and impacts are considered, prevented and mitigated at all stages of the project-cycle, with special attention given to fragile and conflict-affected settings. The strategy should clearly spell out how the Bank will promote and implement a human rights-based approach among its stakeholders, clients and counterparts. In order to achieve that, ADB should employ sound human rights due diligence at project level, undertake Human Rights assessments, quick response mechanisms and numerous already available Human Rights tools. The Bank should consult with relevant stakeholders on best approaches to make the requirements for HR protection part of the client’s obligation under the new Safeguards Policy. 12. Ensure safe and free from retaliation space for the stakeholders to raise their concerns under the consultations process. Comprehensive risk assessment and mitigation plan should be developed for every online and offline event of stakeholder engagement, considering the national and/or group-specific context. The participants, in particular, the affected persons and communities should be properly informed about any potential risks and mitigation measures developed by the ADB to ensure their security.