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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. Frequently Asked Questions History Network Structure International Committee International Secretariat FAQ Ano ang NGO Forum sa ADB? Ang NGO Forum on ADB ay isang network ng civil society organizations (CSOs) na sumusubaybay sa mga proyekto, programa, at patakaran ng Asian Development Bank (ADB) at ng Asian Infrastructure Investment Bank (AIIB). Ang Forum ay aktibo mula noong 1992. Ang forum ay tumutulong sa proyekto, programa at/o mga kampanyang tukoy sa patakaran na pinamumunuan ng mga miyembro nito, at nagsasagawa ng mga workshop sa pagbuo ng kapasidad. Ang NGO Forum sa ADB ay HINDI tumatanggap ng pera mula sa ADB at hindi rin ito bahagi nito sa anumang paraan. Ang Forum Secretariat ay nakabase sa Quezon City, Philippines.

PAKISTAN BANGLADESH INDIA INDONESIA PHILIPPINES Isang online bulletin system at page ng pagbabahagi ng kaalaman na nakatuon sa pagsubaybay sa Asian Development Bank (ADB) at Asian Infrastructure Investment Bank (AIIB) COVID19 recovery loans at disbursement na maaaring gamitin ng mga stakeholder para sa pagsusuri at pagsusuri. SIMULAN ANG PAGSUNOD PAKISTAN PILIPINAS BANGLADESH INDONESIA

The NGO Forum on ADB is an Asian-led network of civil society organizations (CSOs), based in Asia and the Pacific region. ASIAN DEVELOPMENT BANK (ADB) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030 PROYEKTO MONITORING This section features formal submissions made by NGO Forum on ADB network and allies during the ADB Safeguard Policy review process. It includes joint statements, policy critiques, and detailed recommendations advocating for robust, rights-based, and environmentally sound safeguards. These documents reflect the collective efforts of civil society to influence ADB's policies to better protect communities and ecosystems affected by development projects. The fight for stronger safeguards Forum network recommendations on the ADB website Statement of concern regarding the proposed WB/ADB FMRF and its significance in relation to the ADB ESF Collective Civil Society Statement on ESF Draft: Calling for an Overhaul and immediate redrafting NGO Forum comments on ADB ESF R-paper ADB's Response to the Forum Network's Draft ESF Comments Submission Collective Civil Society Statement on ESF Draft: Calling for an Overhaul and Immediate Redrafting PH CSO Statement re: ADB’s Draft Environmental and Social Framework (ESF) Ripple Effect: Exhibition to Highlight Damaging Impact of Asian Development Bank (ADB) Projects Joint civil society statement for a robust, rights-based and just safeguards policy at the ADB 1 Million Signature for a robust, rights-based and just ADB safeguards policy! Civil Society Input and Recommendations on the Stakeholder Engagement Plan ADB Safeguard Spotlight The Story of ADB Safeguards Related Documents ADB Project Tracker COVID19 Loan Tracker

Stand with affected communities facing displacement and livelihood loss. Support urgent needs while they pursue justice and accountability. COVID-19 COMMUNITY EMERGENCY FUND CLICK DITO SA TULONG Tumatanggap kami ng mga nakakaalarmang ulat na ang mga komunidad na apektado ng proyekto ng ADB at AIIB sa buong Asya, lalo na sa Timog Asya at Timog Silangang Asya ay nasa ganap na krisis. Dahil sa ipinapatupad na lockdown, wala silang trabaho o access sa mga sanitizer at supply ng pagkain. Iniwan silang ganap na lantad at mahina sa pandemya ng COVID-19. Ang mga tugon ng estado ay mabagal at sa ilang mga kaso ay wala. Sinisikap ng aming mga miyembro ang kanilang makakaya upang makuha sa kanila ang mga pangunahing pangangailangan, ngunit sa kabila ng kanilang pinakamahusay na pagsisikap, ang mga mapagkukunan ay umaabot at higit pa ang kailangan. Kailangan namin ang iyong tulong ngayon. Tungkol sa Emergency Fund Tungkol sa Emergency Fund Suporta Mga update Top Recipients SINO ANG TATANGGAP NG SUPORTA Depende sa halaga ng donasyon na makakalap, uunahin ng NGO Forum sa ADB ang pagsuporta sa 1) mga komunidad na apektado ng proyekto na apektado ng ADB at/o mga aktibong proyekto ng AIIB; at 2) mga lokal na kasosyo ng Forum na gumagawa din ng kani-kanilang COVID - 19 na mabilis na pagtugon (hal. pagsasagawa ng food drive, pagbibigay ng mga serbisyo sa transportasyon sa mga healthcare worker, atbp.). Ang Forum ay dadaan sa nasabing monetary support sa mga partner na CSOs. Ang halagang ibibigay sa mga kasosyong CSO ay mag-iiba din sa saklaw at/o ilang sambahayan na apektado. Ang nasabing monetary support ay para sa mabilis na pagtugon upang makatulong na maibsan ang mga epekto ng COVID - 19 sa ating mga kasosyong komunidad. Ang suportang ito ay gagamitin sa pagbili ng mga face mask, sabon, alkohol, sanitizer o food pack. Maghahanda ang partner na CSO ng 1 - ulat sa pahina ng suporta na nagdedetalye kung ano ang binili mula sa halagang ibinigay, ilang sambahayan ang naabot ng nasabing suporta at iba pang mga incidental na gastos na ginamit (hal. transportasyon, atbp.) ALAM KUNG PAANO KA MAKAKATULONG TINGNAN ANG MGA UPDATE Bumalik sa Itaas Ang iyong suporta ay lubos na pinahahalagahan sa pagsisikap na tumugon sa COVID-19. SALAMAT! Maaari mong ideposito ang iyong donasyon gamit ang sumusunod na impormasyon - PANGALAN NG BANGKO: BANK OF THE PHILIPPINE ISLANDS ADDRESS: 114 KALAYAAN AVENUE, DILIMAN, LUNGSOD NG QUEZON, PILIPINAS PANGALAN NG ACCOUNT : NGO FORUM SA ADB, INC. PARA sa USD : 1994-0097-84 | PARA sa EU: 1994-0551-31 PARA SA PHP : 1991-0039-12 SWIFT CODE: BOPIPHMM LUGAR NG PAGBIBIGYAN : 85-A Masikap Extension, Barangay Central, Quezon City 1100, Pilipinas CONTACT NUMBER NG BENEPISYO: +63 2 84361858 | +63 2 89214412 Maaari mo rin kaming suportahan sa pamamagitan ng PayPal *** NGO Forum sa ADB ay hindi nag-iimbak ng sensitibong personal na impormasyon, tulad ng mga mailing address, password ng account, atbp. Mangyaring huwag kalimutan na padalhan kami ng kopya ng iyong deposit slip. Paki-email ito sa secretariat@forum-adb.org . Bumalik sa Itaas Donate SUPORTA

Explore NGO Forum on ADB’s work in South Asia, advocating for accountability, environmental justice, and community rights in ADB-funded projects. Stay updated on campaigns, policy engagements, and grassroots initiatives across the region. ASIAN DEVELOPMENT BANK (ADB) Project Monitoring South Asia Southeast Asia Mekong Central Asia and Caucasus PROYEKTO MONITORING INDIA Kolkata Environmental Improvement Investment Programme The Kolkata Environmental Improvement Investment Programme funded by the Asian Development Bank (ADB) has raised the following issues: More than 300 small shopkeepers are temporarily displaced due to the pending construction to facilitate the sewerage and drainage line along the Mahatma Gandhi Road. The shopkeepers do not have an adequate source of income as of the moment and are unable to access loans as they have no standing assets. The Entitlement Matrix was not explained nor shared as a leaflet to the affected persons (APs). The consultation merely focused on the timeframe of the construction. Bengaluru Metro Rail Airport Line (Phase 2A & 2B) The Bengaluru Metro Rail Project 2A and 2B Airport lines were conceived, presented, and heavily supported in the pre-pandemic era. And hence all the traffic demand analysis, modeling, and forecasting are from a time and lifestyle that we cannot hope to return to. Moreover, it's from when Government restrictions and company policies bound work From Home (WFH) in IT capital Bangalore. In November 2020, the Government of India (GoI) removed all constraints and compliances for the tech industry to work from home (WFH). The PM himself stated - "These steps will further flexibility and productivity." Read Growthwatch's letter regarding the Bengaluru Metro Rail Airport Line (Phase 2A & 2B). INDIA Accelerating Infrastructure Investment Facility Workers in Himachal Pradesh have demanded justice on unpaid wages and other benefits, arguing that the lender – the Asian Development Bank (ADB) – has violated its labor policies, causing a negative impact on a group of 116 union members working on the project. A group of fifteen workers, who were engaged on the ADB-funded Kiratpur-Nerchowk Four Lane Road project in Himachal Pradesh, explained to the ADB’s Compliance Review Panel staff in a conference call that the collapse of the project contractor Infrastructure Leasing & Financial Services (IL&FS) has left them millions of rupees out of pocket. Read More INDIA Wind Power Generation Project The Wind Power Generation Project in Sri Lanka is a US$ 200 million ADB – funded project which accordingly aims to provide increased access to the clean and reliable power supply by 2025. The project, which falls under the energy sector, is said to address environmentally sustainable growth and inclusive economic growth. A total of 39 wind turbines will be erected in the Mannar District area, located in the Northern Province of Sri Lanka. The outputs of this investment project are: Wind power generation capacity increased System reactive power management improved and Capacity of CEB in project engineering design review and supervision strengthened. Read More SRI LANKA SRI LANKA Mahaweli Water Security Investment Program The Upper Elahera canal project funded by the Asian Development Bank has committed serious environmental safeguard violations including the construction of a 1.7 km access road inside the Beligama forest which is part of the Knuckles conservation forest without adhering to the environmental safeguards as per the safeguarding policy statement 2009. The construction company Sinohydro Corporation Ltd involves in these environmental safeguards violations. Although the environmental impact has been identified for this 1.7 km section, the construction company has not followed the conditions set during the project approval to protect the environment. The company has already cleared this sensitive forest stretch and dump debris and soil to the riverside and constructed another 1 km of the road across non-approved stretch. SRI LANKA Southern Transport Development Project The Southern Transport Development Project (STDP) is an ADB co-financed project, which includes the construction of a 128-km controlled-access expressway from Colombo to the southern city of Galle, which will link up with an existing coastal road in Matara. ADB is providing a US$ 90 million loan approved in November 1999 for 55 km of this expressway, with Japan Bank for International Cooperation (JBIC) providing funds for the rest of the stretch. The construction of the road aims to help catalyze economic growth in the southern region of Sri Lanka in general and reduce traffic and accidents on the coastal road. Read More BANGLADESH Phulbari Coal Project The Phulbari Coal Project involves the extraction of coal using open-pit mining method. It involves the construction of a 500-MW power plant. According to the ADB, at full production, about eight million tons of coal will be transported by rail and barges to an offshore reloading facility located in Akram Point. Some four million tons will be exported to India via railway. The remaining three million tons will be for domestic use. However, as much as the economic benefits it intends to bring to Bangladesh, the project will not only pose a health hazard but displace around 50,000 people. Likewise, Akram Point, where the reloading facility will be located, is in Sundarbans Mangrove Forest – a UNESCO-declared world heritage site. Transportation of millions of tons of coal through Sundarbans and Akram Point will also have serious environmental impacts Read More BANGLADESH Sundurban Biodiversity Conservation Project On January 22 and 23, Review and Planning meetings of the SBCP Watch Group were held in presence of Mr. Sardar Arif Uddin, Associate Program Coordinator, Southwest Region, of AAB at the Conference Room of CDP. Resolutions were adopted to enhance the membership of the SBCP, collect and prepare various SBCP related documents, prepare a Position Paper of the SBCP Watch Group and prepare to face the Asian Development Bank at its AGM to be held in May next at Istambul in Turkey, were adopted at the meeting. Mr. Sardar Arif Uddin also presented the plan for the Second Phase of the activities of the SBCP Watch Group and Budget for the same. CDP also compiled Newspaper Clippings on the activities of the SBCP Watch and published a book, entitled: “Sundarbans Biodiversity Conservation Project: Peoples’ Opinions in Bangladesh.” Read More Melamchi Water Supply Project Six years after its conception, the Melamchi Water Supply Project (MWSP), the Asian Development Bank’s pet project in Sindhupalchowk District, Nepal, is still mired in controversy. Three of the project’s original funding agencies—the World Bank, Swedish International Development Agency (SIDA) and Norwegian Agency for Development (NORAD) —had pulled out in the last three years brought about by several pressing issues. In fact, the water project has been on the donors’ priority list in the last two decades but was never pursued due to conflict of interests among donors, mainly between the World Bank and the ADB. NEPAL Read More NEPAL West Seti Hydroelectric Project The West Seti Hydroelectric Project is a 750 MW dam project in western Nepal (located in Baitadi, Bajhang, Dadeldhura, and Doti Districts), which has been planned by an Australian company, Snowy Mountains Engineering Corporation (SMEC). The estimated project cost is 1.2 billion dollars, and the project is expected to receive loans and political guarantees by Asian Development Bank (ADB), Multilateral Investment Guarantee Agency (MIGA), Export and Import Bank of China, Bank of China, Infrastructure Leasing, and Export Corporation (India), Industrial Bank of China, China Export and Credit Insurance Corporation (SINOSURE). All the electricity produced will be transferred to India by the Power Trade Corporation (PTC). As a royalty, 10 % of the produced electricity (or equivalent cash) is expected to be provided to the Government of Nepal. This project has been set under Category A, as per the ADB Environment Policy, and the first Environmental Assessment (EIA) report was carried out in 1999. NEPAL Kali Gandaki “A” Hydroelectric Project Informed officials about a nearby landslide that damaged five houses. Rising to the call of duty, at half-past seven in the morning the District Administration and Police Officers arrived and took stock of the situation. The nearby cracked surfaces served as a reminder of the devastating Gorkha earthquake the previous month. More than 250 villagers were relocated to a safe spot. More landslides ensued the following day as tents were provided for affected residents. Whilst sleeping in the temporary camp, the residents of Basari village got another rude shock at half-past two in the morning. This time an even more colossal landslide formed a wall of mud and rock that blocked the Kali Gandaki River. There was pandemonium as people panicked fearing for their lives. Local police made announcements on loudspeakers asking people in Mustang, Myagdi, Baglung, Parbat, Gulmi, Syangja, Tanahun, and Nawalparasi districts downstream to remain on high alert. The landslide dammed the river and blocked almost the entire flow, which resulted in a 2-km long artificial backwater lake. The landslide occurred as a nearby ridge had developed cracks after the earthquake. NEPAL Tanahu Hydropower Project Indigenous communities affected by the Tanahu Hydropower Project in Nepal have filed complaints with independent watchdogs of the Asian Development Bank (ADB) and the European Investment Bank (EIB) -- two co-financiers of the project -- requesting an independent mediation process. The communities have alleged failure to uphold free, prior, and informed consent and inadequate compensation for loss of lands and livelihoods. At least 32 affected families or landowners organized under the Directly Inundation Affected Peoples Collective Rights Protection Committee have called for ‘land for land’ and ‘house for house’ compensation, re-survey of land left out during the Detailed Measurement Survey of the project, and free, prior and informed consent in the project process, among their ten demands, they have submitted to the ADB and the EIB. Read More PAKISTAN Chashma Right Bank Irrigation The Chasma Right Bank Irrigation Project (CBRIP) was approved by the Asian Development Bank (ADB) in December 1991. It involves the construction of a 274-kilometer canal along the Indus River that will run through two districts in Punjab and Northwest Frontier provinces. According to the Bank, it will irrigate 606,000 acres of land in D.I. Khan and D.G. Khan Districts in central Pakistan. The project primarily aims to provide a dependable perennial irrigation supply, ensure efficient distribution of water and provide necessary drainage and flood relief. Aside from the main canal, 72 distribution canals, 68 cross-drainage structures, and 91 bridges will be constructed. PAKISTAN M4 Gojra– Shorkot– Khanewal Project The entire M4 highway is a 240 km road which will construct: 15 interchanges 23 flyovers/underpasses 11 bridges 19 underpasses 191 pipe culverts 55 WCC boxes and gas culverts There will be two bridges that will be constructed across 2 main surfaces of water bodies that irrigate agri-lands: River Ravi and Sadhnai Canal. There will be a displacement of 3,429 households from the use of 1,616.7 acres of land of which 86 % is privately-owned agricultural land and will require the cutting of 91,661 trees. Photo © tribune.com.pk

The NGO Forum on ADB is an Asian-led network of civil society organizations (CSOs), based in Asia and the Pacific region. PROYEKTO MONITORING 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 ASIAN DEVELOPMENT BANK (ADB) 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. PROYEKTO MONITORING 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 ASIAN DEVELOPMENT BANK (ADB) 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. PROYEKTO MONITORING 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 ASIAN DEVELOPMENT BANK (ADB) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030

Monitoring ADB’s actions in Asia-Pacific to fight harmful projects, protect communities, and ensure sustainable, people-centered development. ASIAN DEVELOPMENT BANK (ADB) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030 PROYEKTO MONITORING SOUTH ASIA Read More SOUTHEAST ASIA Read More MEKONG Read More CENTRAL 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. ASIAN DEVELOPMENT BANK (ADB) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030 PROYEKTO MONITORING 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

RESOURCES 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 Disyembre Setyembre Hunyo Marso 2019 Disyembre Setyembre Hunyo Marso Naghahanap ng mas lumang isyu sa Bankwatch? Humingi ng kopya sa secretariat[at]forum-adb.org.

The NGO Forum on ADB is an Asian-led network of civil society organizations (CSOs), based in Asia and the Pacific region. PROYEKTO MONITORING 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. ASIAN DEVELOPMENT BANK (ADB) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030