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Explore ADB Safeguard Violations in Energy Projects This interactive page provides a visual overview of safeguard violations linked to ADB–funded energy projects in South Asia. How to use this dashboard? Click on any item—such as a country, safeguard category, or type of violation—to view detailed project information and related issues. Click the same item again to return to the full regional overview. Use the filters and visual tools to explore where and how safeguard breaches have occurred in ADB’s energy portfolio across South Asia. ADB Energy Investments In South Asia Next

Special Publications Нашрияҳои махсус ЗАХИРАХО Соатҳои бонкӣ | Ҳисоботи солона | Лоиҳа мухтасар | Китобҳои роҳнамо Парешонҳои хатарнок Зарар нарасонед Дар торикй Regional Overview of Country Safeguard Systems to Mitigate Trans boundary Infrastructure Mega Project Impacts : Mongolia Regional Overview of Country Safeguard Systems to Mitigate Trans boundary Infrastructure Mega Project Impacts : Indonesia Regional Overview of Country Safeguard Systems to Mitigate Trans boundary Infrastructure Mega Project Impacts : Myanmar Regional Overview of Country Safeguard Systems to Mitigate Trans boundary Infrastructure Mega Project Impacts : South Asia and Sri Lanka Assessment of the ADB’s Energy Policy: Undermining International Climate Commitments ◄ 1 / 1 ► Please reload 2nd AIIB ESS Critique AIIB Energy Strategy Critique RISK AND RESILIENCE: Mainstreaming Climate Change Into the Environmental Impact Assessment Process The ADB in Burma: Behind the Scenes Roads to Destruction ADB’s Contradictory Roads, Biodiversity and Plantations Activities in Lao PDR or How Did You Know We Wanted Ecocide? ◄ 1 / 1 ► Please reload

The NGO Forum on ADB is an Asian-led network of civil society organizations (CSOs), based in Asia and the Pacific region. МОНИТОРИНГИ ЛОИҲА Latest News Sign the 1M Petition ADB Project Tracker Media NGO Forum on ADB questions ADB’s intent to shift towards using country safeguards systems without any ‘assessment’ and ‘equivalency’ with its own safeguards systems as presented by the Strategy and Policy Department of the ADB. This alarming move towards using country systems prematurely will have disastrous impacts on local communities and the environment especially in autocratic regimes where civil society voice is suppressed and persecuted, and national instruments are riddled with corruption and weak implementation. ADB in doing so will also be in violation of its own ADB Safeguards Policy Strategy SPS 2010, where it clearly indicates ‘equivalency’ and ‘assessment’ to be conducted for Country Systems with ADB standards before they are considered for use in any ADB project. In ADB’s own study on Country Systems in 2015, it indicates that in six upper-middle-income countries UMICs, the use of country systems are not feasible as they are far from ADB SPS 2010 standards. The ADB is faced to provide competitive lending rates with the rise of new banks and abruptly moving towards using Country Systems is a way by which the Bank is trying to reduce loan approval times and “costs” by compromising due diligence requirements which put human rights, public safety, environmental sustainability and national economies at risk. Read the Strategy 2030 related documents below : 21 Aug 2018 | Pillars for the Future of Development Finance in Asia 08 May 2018 | Joint Submission of Comments on ADB’s Draft Strategy 2030 02 Feb 2017 | ADB Strat 2030 Letter 29 Mar 2017 | ADB response to letter regarding ADB's new corporate strategy 30 Jun 2016 | ADB criticized for holding questionable consultations on its new corporate strategy БОНКИ ОСИЁИ РУШДИ (БОР) 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. МОНИТОРИНГИ ЛОИҲА Latest News Sign the 1M Petition ADB Project Tracker Media 2009 after the approval of the new ADB’s Accountability Mechanism (AM) was approved in December 2003, replacing the 1995 Inspection Function. Although a review of the policy was scheduled in 2006, it was postponed until 2008 and later rescheduled. The ADB officially started its policy review when ADB President Haruhiko Kuroda made an announcement during its Annual Meeting in Tashkent in May 2010. The ADB conducted a series of multi-stakeholder consultations in Asia, Europe, and the United States from September to November 2010. It also held consultations with affected people in selected countries. In April 2011, Forum submitted its comments on the consultation draft policy paper. Civil society organizations, however, criticized the ADB for coming up with a draft Working Paper–a draft policy version submitted to the ADB Board of Directors for review–two days after the deadline for submission of public comments on the consultation draft policy paper. In May 2011, after Forum’s continuous pushing and lobbying, the bank decided to put the review process on the right track by inviting public comments on the draft Working Paper. In June 2011, Forum submitted its comments on the first Working-Paper. In July, ADB released its second Working-Paper which is currently open for public comments. Forum members have been using the AM to register local communities’ complaints on the Bank’s lapses in terms of its policies, programs, and projects. While there was not a single complaint filed in 2008, out of the 13 cases in 2009, four of which were filed by Forum members. Accountability mechanism related documents - 21 Oct 2019 | NGO Forum on ADB Comments: Safeguard Compliance and Accountability Mechanism Framework 17 Mar 2019 | ADB’s 10 years of Accountability Mechanism is not worth celebrating 17 Jan 2019 | Does ADB's Accountability mechanism work? 14 Nov 2010 | Review on Accountability Greater Mekong Subregion: Mekong Tourism Development Project 14 Nov 2010 | Holding ADB Accountable: A look at the Present Accountability Mechanism 14 Nov 2010 | Review on Accountability Mechanism Sixth Road Project: Not Eligible 12 Nov 2010 | Accountability Counsel Comments on the Asian Development Bank Accountability Mechanism Policy Review 14 Sep 2010 | Submission to the Accountability Mechanism Review 09 Sep 2010 | Effectiveness of the Accountability Mechanism in Central Asia and the Caucasus БОНКИ ОСИЁИ РУШДИ (БОР) 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. МОНИТОРИНГИ ЛОИҲА Latest News Sign the 1M Petition ADB Project Tracker Media WATCH Unpacking the Delivery of ADB’s Safeguard Policy Statement 8 May 2019 | Nadi, Fiji БОНКИ ОСИЁИ РУШДИ (БОР) 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. БОНКИ ОСИЁИ РУШДИ (БОР) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030 МОНИТОРИНГИ ЛОИҲА 01 ESF December 2024 02 ESF Policy Paper 03 Environmental and Social Framework (September 2024 - Revised Draft) 04 ESF Consultation Draft 05 Safeguard Policy Statement Review and Update Policy Architecture Study 06 Safeguard Policy Statement Review and Update Stakeholder Engagement Plan 07 Safeguard Policy Statement Review and Update Stakeholder Engagement Plan (Version 2) 08 Access Information Policy 2018 ADB Safeguard Spotlight The Story of ADB Safeguards Related Documents ADB Project Tracker COVID19 Loan Tracker 2010 Forum’s Comments on the Operations Manual of the new Safeguard Policy Statement (February 2010) 2009 OM Language Recommendations of the Forum (31 July 2009) Comments on the Forum on R-Paper of the Safeguard Policy Statement (14 July 2009) Detailed recommendations for the improvement of the SPS R-paper (15 July 2009) Safeguard Policy Statement: updated Safeguards (June 2009) Comments on the 2nd draft Safeguard Policy Statement United Nations Educational, Scientific, and Cultural Organization (UNESCO), 8 January 200 2008 Comments on the 2nd draft Safeguard Policy Statement US Department of Treasury, 17 December 2008 US Department of Treasury, 7 December 2008 Gender Action, 5 December 2008 Public Services International, 4 December 2008 International Accountability Project, 4 December 2008 Consolidated IP-SPU workshop participants, 4 December 2008 Forest Peoples Programme, 4 December 2008 NADI, 4 December 2008 World Resources Institute, 4 December 2008 Bank Information Centre, 4 December 2008 NGO Forum on ADB, 4 December 2008 NGO Forum on ADB’s initial comments on the draft Safeguards operations manual, 4 December 2008 Centre for Environmental Justice, 4 December 2008 Environmental Law Alliance Worldwide (E-Law), 3 December 2008 Environmental Defense Fund, 2 December 2008 Central Asia and Caucasus NGOs, 27 November 2008 International Network on Displacement and Resettlement, 20 November 2008 Japan Center for Sustainable Environment and Society (JACSES), 13 November 2008 ADB’s response to Forum’s proposed agenda for the second round SPU consultation, 22 August 2008 Forum’s proposed agenda for the second round SPU consultation, 25 July 2008 Forum’s response to ADB’s consultation plan, 4 July 2008 Safeguards Down the Drain, Hemantha Withanage ADB Environmental Safeguards in Reverse Gear!, Avilash Raoul Country Safeguard Systems approach at the ADB, Jennifer Kalafut Involuntary Resettlement & the Asian Development Bank, Joanna Levitt Safeguarding Indigenous Peoples’ Rights, Rowena Soriaga Forum’s comments on the Draft SPS, 28 April 2008 BIC’s Comments on the Draft SPS, 30 March 2008 E-Law’s Comments on Draft SPS, 21 March 2008 Downing and Scudder Expert Opinion on ADB SPU, 20 March 2008 ADB’s response to Forum’s Call for Revision of SPS, 7 March 2008 Burmese Civil Society Groups’ Letter to the ADB on SPU, 4 March 2008 Vietnam NGOs’ letter on SPU consultation, 25 February 2008 IAITPTF’s Letter to the ADB on the Draft Safeguard Policy Statement, 22 February 2008 IAP’s Comments on the Draft Safeguard Policy Statement, 19 February 2008 German Economic Minister Letter on the ongoing SPU, 11 February 2008 Forum’s letter to ADB President calling for the revision of the SPS draft, 7 February 2008 Forum’s letter to SPU Team calling for the revision of the SPS draft, 7 February 2008 2007 Act Now! Demand for Greater Safeguards, 23 November 2007 ADB’s Country Safeguards System, November 2007 ADB’s response to Forum’s letters on SPU process, 6 November 2007 Forum’s letter to ADB regarding the SPU Process, 25 October 2007 Forum’s letter to ADB regarding the SPU Process, 24 October 2007 Consultation Draft of the Safeguard Policy Statement, October 2007 Forest People’s Programme’s comments on the OED Special Evaluation Study on the Indigenous Peoples Policy In Search of Middle Ground: Indigenous Peoples, Collective Representation and the Right to Free, Prior and Informed Consent, Annex to FPP’s comment to the OED Special Evaluation Study on IP Policy, by Marcus Colchester and Fergus MacKay, Forest Peoples Programme, August 2004 A Call to Safeguard Equitable and Sustainable Development in Asia: Collective statement by NGO Forum on ADB regarding the ADB Safeguard Policy Update, March 2007 2006 Comparative Matrix – Environment Policy Weekend Standards Yes to Accountability, 20 April 2006 Open Letter to the ADB president on the Safeguard Policy Update, 16 March 2006 Comparative Matrix – Indigenous Peoples Policy Comparative Matrix – Involuntary Resettlement Policy ADB Resettlement Policy Comparative Matrix, International Accountability Project, November 2006 Snapshots of ADB Disasters Development Debacles Civil Society Says, “No to 2005 ADB Discussion Note- October 2005 ADB Response by Mr. Albab Akanda, Team Leader- 28 September 2005 Civil Society Organization’s letter to ADB President Haruhiko Kuroda – 22 July 2005 Board Approval for the Consolidated Review of the ADB Safeguards Policies – July 2005 Window Dressing for Business? The Asian Development Bank Safeguard Policy Implementation Review by Grace Mang ADB and the Environment (NGO FORUM ON ADB Publication) Indigenous people and the ADB (NGO FORUM ON ADB Publication ) ADB Documents ADB Response by SPU Team on discussion note (28 September 2005) Discussion Note: Safeguard Policy Statement (October 2005) Consultation Draft of the Safeguard Policy Statement (October 2007) ADB’s response to Forum’s Call for Revision of SPS (7 March 2008) ADB’s response to Forum’s proposed agenda for the second round SPU consultation (22 August 2008) Preliminary Draft Operations Manual Section, Draft Safeguards Review Procedures (3 October 2008) ADB SPU: Report on Stakeholder Consultations (Comments-response matrix) (8 October 2008) 2nd Draft Safeguard Policy Statement (October 2008) Working Paper: Safeguard Policy Statement (January 2009) Safeguard Policy Statement (June 2009) Statement (October 2007) Safeguards Operations Manual (January 2010) Older Safeguards Documents

Tracking the Asian Infrastructure Investment Bank (AIIB) to expose harmful projects and policies, and advocate for transparency, justice, and sustainable development in Asia-Pacific. БОНКИ ОСИЁИ РУШДИ (БОР) Project Monitoring Energy Campaign Project-affected People's Mechanism (PPM) AIIB Annual Meeting МОНИТОРИНГИ ЛОИҲА SOUTH ASIA Read More SOUTHEAST ASIA Read More

The NGO Forum on ADB is an Asian-led network of civil society organizations (CSOs), based in Asia and the Pacific region. БОНКИ ОСИЁИ РУШДИ (БОР) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030 МОНИТОРИНГИ ЛОИҲА Latest News Latest Events/Activities Civil society slams ADB’s “clean energy” claims at ACEF 2025 As the Asian Development Bank marks 20 years of the Asia Clean Energy Forum (ACEF), civil society groups across Asia are calling it two decades of greenwashing. In a powerful joint statement, they denounce ADB’s continued backing of fossil fuels, harmful technologies, and corporate polluters, warning that false solutions like gas, mining, and incineration are worsening the climate crisis. With the bank’s energy policy review underway, they demand a real shift toward justice, equity, and people-powered renewable systems. Read Press Release

The NGO Forum on ADB is an Asian-led network of civil society organizations (CSOs), based in Asia and the Pacific region. МОНИТОРИНГИ ЛОИҲА Latest News Sign the 1M Petition ADB Project Tracker Media NGO Forum on ADB Comments: Safeguard Compliance and Accountability Mechanism Framework for Investments Supported by Financial Intermediaries In Forum’s experience, there are several fundamental problems in ensuring FI Accountability to Safeguards – Project cycle bound timely release of project information in a meaningful manner for local peoples FIs need to ensure that environmental and social due diligence is implemented at the highest standards by their clients On issues of non-compliance, an independent and responsive redress mechanism has to be in place to ensure remedy for affected peoples. Keeping these three principles in mind the following comments have been made to the AMF- In the introductory section of the AMF, the lack of implementation of Equator Principles has been cited as a clear gap in FI accountability. We would recommend that the shift from guidelines for FIs to binding requirements should be emphasized in this section to strengthen the conceptual framework for this AMF. In line with comments from Accountability Counsel, we re-echo the need for learning to be upfront in this document for the AMF (Section 12, pg 4). For the AMF to work effectively it has to be able to learn from each case and make the necessary reforms to strengthen implementation. The issue of lessons learned and feedback loops built into the AMF system to help reform the structure will be critical to bringing diverse types of FI’s to compliance. On the issue of FI Sub-project categorization (pg.8) there is a need to ensure that a comprehensive ESIA is conducted to ensure the ‘Big B’ Category projects are deemed Category A. This is a potential risk especially for Infrastructure Funds, examples can be drawn from the Emerging Asia Fund of the AIIB and IFC, which has been tapped by Summit Power Group to retrofit several coal plants and build 4 new power generation facilities, which are fossil fuel based. The impacts from these projects will be long term and immediate and will require comprehensive ESIAs to ensure Safeguards are implemented. FIs and there parent funding institutions such as commercial banks and multilateral banks should have a strict monitoring role over their clients on environmental and social due diligence. The current practice of client-led safeguarding and self- reporting is no longer a viable model to ensure that AMF objectives are reached, thus we strongly recommend that monitoring and evaluation roles by FIs and their parent financial institutional investors should have an overseeing function. This is maybe done through further elaborating on a governance framework for FIs and their FI Clients, with detailed monitoring requirements in place. We are noticing for both ADB and AIIB projects that the Grievance Redress Mechanisms are often not effective at the local level. For MDBs it has been a real challenge to ensure that local GRMs have worked effectively; this will be a bigger challenge for an FI client to ensure. In this case, we recommend that project level GRMs should be – Meaningfully accessible for local communities Ensure complainants protection from backlash and retaliation Ensure remedial response The paper recognizes the shortcomings of GRMs - "However, GRMs are often poorly designed or implemented, and thus create mistrust and conflict between communities and the project executing agency. Finally, it must be noted that project-level GRM is not a substitute for an accountability mechanism at the institutional (financial intermediary) level, because the GRM cannot determine whether the financial intermediary has complied with its own environmental and social policies, standards, and procedures." Thus it has to be explicitly stated that accessing local GRMs should not be made a pre- requisite for local communities to trigger the Accountability Mechanism for an FI project. As mentioned earlier the fundamental problem with FI non-compliance to Safeguards is the lack of Time Bound Disclosure of project information to local people. At present local communities have no way of assessing whether FI subprojects are indeed FIs and what policies and mechanisms are entailed in their operations. From a community perspective, the following information has to be provided pre-project approval – Area and scale of the project Clear description of project cycle, construction, environmental and social impacts Clear assessment of project benefits sharing, compensations and allocations Clear understanding on rights, privileges and redress mechanisms for communities in cases of violations. All of language needs and ensuring that poor and vulnerable groups such as women, children and people with disabilities are made aware of all project related information. This is where the governance structure of this AMF will prove to be critical to ensure that Clients are complying with the disclosure needs at the local level. Provisions should also be made upstream in the project cycle to ensure that information disclosure needs are all met before a project is approved for implementation. The Forum re-echos Accountability Counsels recommendation on following the best practice example from the Green Climate Fund - which works with FIs, or accredited entities – The GCF has adopted a high degree of disclosure in line with international best practice, including time-bound disclosure of crucial project information – such as environmental and social impact assessments – ahead of approval. The degree and timing of disclosure are calibrated according to the risk profile of the investment: with more and better disclosure for the highest risk (Category A). The following excerpts from its 2016 Information Disclosure Policy describe the degree of disclosure: “Environmental and social reports. With respect to the project and program funding proposals that have an environmental or social impact, the Accredited Entities (AE’s) shall disclose and announce to the public and, via the Secretariat, to the Board and Active Observers: in case of Category A projects, the Environmental and Social Impacts Assessment (ESIA) and an Environmental and Social Management Plan (ESMP) at least 120 days in advance of the AE’s or GCF’s Board decision, whichever is earlier; in the case of Category I-1 programs, the Environmental and Social Management System (ESMS)2 at least 120 days in advance of the AE’s or GCF’s Board decision, whichever is earlier; in the case of Category B projects, the ESIA3 and an Environmental and Social Management Plan (ESMP)4 at least 30 days in advance of the AE’s or GCF’s Board decision, whichever is earlier; and in the case of Category I-2 programs, the ESMS at least 30 days in advance of the AE’s or GCF’s Board decision, whichever is earlier.” The Forum recognizes the independence embedded in the structure proposed in this AMF and would make the following recommendations on the mechanism proposed- In the submission of a complaint, there should be a provision for complaints to be filed by international and regional representatives as authorized representatives for local and in-country representatives who are unable to step forward due to security risk and conflict scenarios. In cases where the IRM has proved that there have been issues on non-compliance, then all consultations between the client and the community MUST have the IRM present to ensure power equity in information exchange. This has to be an integral part of ensuring that a complaint process and remedial action are done objectively. In it’s entirety this AMF is an innovative and needed effort in holding FIs accountable. БОНКИ ОСИЁИ РУШДИ (БОР) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030

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