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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. 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

The Sandra Smithey Community Emergency Fund is established in honor of Sandra Smithey. Sandra was the Former Program Officer of the Mott Foundation and the Director of Programs and Philanthropic Engagement at Shine Campaign. Sandra inspired the Forum network members to make a difference in the world. She was a force of nature, ensuring that advocacies about the environment, climate, and human rights were advanced. The fund will be used for emergency relief and distributed to project-affected communities through the Forum network member organizations. For Bank donations - NAME OF BANK : BANK OF THE PHILIPPINE ISLANDS ADDRESS : 114 KALAYAAN AVENUE, DILIMAN, QUEZON CITY, PHILIPPINES ACCOUNT NAME : NGO FORUM ON ADB, INC. FOR USD : 1994-0097-84 | FOR EU : 1994-0551-31 FOR PHP : 1991-0039-12 SWIFT CODE : BOPIPHMM BENEFICIARY ADDRESS : 85-A Masikap Extension, Barangay Central, Quezon City 1100, Philippines BENEFICIARY CONTACT NUMBER : +63 2 84361858 | +63 2 89214412 Please email us a copy of the deposit slip or bank transaction slip for transparency purposes. and updates. You may send it to secretariat [at] forum-adb.org.

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Explore the timeline of NGO Forum on ADB, highlighting key milestones, advocacy efforts, and achievements in promoting accountability, sustainability, and social justice in ADB and AIIB operations. Based in Quezon City, the Forum has been a leading voice for civil society since 1992. NGO FORUM SA ADB SA MGA TAON 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 1991 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 1994 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 1997 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 2000 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 2004 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 2008 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 2011 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 2016 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 2018 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 2020 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 2022 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB). NGO Forum sa ADB ay unang itinatag bilang NGO Working Group (NWG) sa ADB. 2023 1988 Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) at Environmental Policy Institute (EPI) pumasok sa partnership address ng multilateral development bank (MDB) na mga isyu na may kaugnayan, na tumututok sa Asian Development Bank (ADB).

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. ASIAN DEVELOPMENT BANK (ADB) Project Monitoring Energy Campaign Project-affected People's Mechanism (PPM) AIIB Annual Meeting PROYEKTO MONITORING 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 PROYEKTO MONITORING 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

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 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.

Tracking the Asian Infrastructure Investment Bank (AIIB) to expose harmful projects and policies, and advocate for transparency, justice, and sustainable development in Asia-Pacific. ASIAN DEVELOPMENT BANK (ADB) Project Monitoring Energy Campaign Project-affected People's Mechanism (PPM) AIIB Annual Meeting PROYEKTO MONITORING 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. PROYEKTO MONITORING ADB Safeguard Spotlight The Story of ADB Safeguards Related Documents ADB Project Tracker COVID19 Loan Tracker The Asian Development Bank (ADB) recently concluded its review of the 2009 Safeguard Policy Statement (SPS), a framework designed to prevent harm to communities and the environment from development projects. While the review aimed to address emerging challenges and align with international best practices, civil society organizations (CSOs), notably NGO Forum on ADB, have expressed concerns about the process and outcomes. NGO Forum on ADB, a network monitoring ADB's projects and policies, actively engaged in the safeguard policy review process. They, along with other CSOs, raised issues regarding the draft Environmental and Social Framework (ESF), highlighting shortcomings such as - Lack of clear accountability mechanisms Insufficient stakeholder engagement Absence of a human rights-based approach Weakened environmental and social protections Dilution of gender considerations Inadequate climate change standards Opaque financial intermediary lending practices These organizations urged the ADB to overhaul the draft ESF to ensure it reflects forward-looking safeguards grounded in international human rights and environmental standards. NGO Forum on ADB emphasized the need for the ADB to prioritize the well-being of affected communities and the environment over the interests of private sectors and borrowing governments. They called for meaningful consultations, transparency, and robust human rights protections in ADB's operations. As the ADB moves forward with implementing the updated safeguard policies, it is imperative that the bank listens to the voices of affected communities and civil society organizations. Strengthening environmental and social safeguards is essential to ensure that development projects contribute to equitable and sustainable outcomes, rather than exacerbating existing inequalities or environmental degradation. Why Engage with Safeguards? Engaging with ADB's safeguard policies is crucial for ensuring that development projects do not harm communities or the environment. Active participation by civil society and affected communities can lead to more equitable and sustainable outcomes. By understanding and monitoring safeguard implementation, stakeholders can hold ADB and its clients accountable, ensuring that projects adhere to agreed-upon standards and genuinely contribute to development goals. Overview of ADB's Safeguard Policy Statement (2009) The SPS outlines ADB's commitment to - Avoid, minimize, or mitigate adverse environmental and social impacts of projects. Enhance environmental and social benefits. Support borrowers in strengthening their safeguard systems and implementation capacity. The SPS applies to all ADB-financed and/or ADB-administered projects, including private-sector operations. Key Safeguard Areas Environment - Projects must avoid, minimize, or mitigate adverse environmental impacts. Environmental assessments are required, and information must be disclosed to stakeholders. Involuntary Resettlement - The policy aims to avoid involuntary resettlement where possible. When unavoidable, it ensures that displaced persons receive assistance to improve or at least restore their livelihoods and standards of living. Indigenous Peoples - ADB seeks to ensure that Indigenous Peoples receive culturally appropriate benefits from projects and that adverse impacts are avoided or mitigated. Country Safeguard Systems (CSS) ADB may use a country's existing safeguard systems for project implementation, provided they are equivalent to ADB's SPS and adequately implemented. This approach aims to strengthen and use the borrower's systems for managing environmental and social risks. Recent Developments ADB is currently reviewing and updating its SPS to address emerging challenges and align with international best practices. The review process includes consultations with stakeholders to enhance protections related to climate change, gender-based violence, disability inclusion, and other areas. ASIAN DEVELOPMENT BANK (ADB) Project Monitoring Energy Campaign Safeguards Public Information Policy Accountability Mechanism Strategy 2030

Explore how communities and civil society organizations engage with the AIIB’s Project-affected People’s Mechanism (PPM), with analysis from NGO Forum on ADB highlighting gaps in accessibility, transparency, and accountability in addressing project-related harms. ASIAN DEVELOPMENT BANK (ADB) Project Monitoring Energy Campaign Project-affected People's Mechanism (PPM) AIIB Annual Meeting PROYEKTO MONITORING The AIIB Project-affected People’s Mechanism (PPM) was established as the bank’s accountability framework to address complaints from communities harmed by AIIB-financed projects, aiming to provide redress and uphold the bank’s Environmental and Social Framework (ESF) commitments. However, civil society organizations have raised serious concerns about its accessibility, independence, and effectiveness. Since its inception in 2019, only a handful of cases have been formally registered—most notably, the 2022 complaint filed by CLEAN and the NGO Forum on ADB regarding the Bhola IPP project in Bangladesh, which alleged coerced land acquisition, environmental damage, and lack of consultation (CLEAN & Forum on ADB, 2022). Critics argue that procedural barriers—such as the requirement to exhaust project-level grievance mechanisms first—and vague timelines for response undermine the PPM’s credibility (Urgewald, 2023). Furthermore, the PPM is structurally embedded within AIIB’s management, raising doubts about its independence compared to more autonomous accountability mechanisms at institutions like the ADB or World Bank (Recourse, 2022). As AIIB expands its project portfolio, particularly in sectors like fossil gas, large hydro, and waste-to-energy, civil society advocates urge the bank to reform the PPM to ensure it can meaningfully serve communities affected by harmful infrastructure and to strengthen enforcement of safeguard violations, not merely mediate them. References: CLEAN & Forum on ADB. (2022). Formal complaint to AIIB on Bhola IPP project. https://www.forum-adb.org Recourse. (2022). Accountability in Multilateral Development Banks: Comparative Analysis. https://www.re-course.org Urgewald. (2023). AIIB Watch: North Dhaka Waste-to-Energy. https://www.urgewald.org FAQs on AIIB's PPM What is the PPM? The PPM is the AIIB’s accountability mechanism, created to address complaints from individuals or communities who believe they have been adversely affected by an AIIB-financed project. It is designed to uphold the bank’s Environmental and Social Framework (ESF). Who can file a complaint? Any two or more affected individuals (or their representative) who believe that an AIIB project has caused them harm related to environmental or social issues may submit a complaint to the PPM. What issues can the PPM investigate? The PPM can examine whether AIIB has failed to follow its own Environmental and Social Policy, leading to harm. It does not address corruption, procurement disputes, or policy disagreements. Is it independent of AIIB management? This is a point of contention. While the PPM is technically separate from project operations, it is structurally housed within AIIB’s management, unlike more independent mechanisms at other multilateral banks (Recourse, 2022). What’s the process for submitting a complaint? Complainants must first attempt to resolve issues through the Project-level Grievance Redress Mechanism (GRM). If unresolved, they can then file a request for compliance review or problem-solving with the PPM. Are there any real examples of PPM complaints? Yes. In 2022, civil society groups CLEAN and Forum on ADB filed the first known complaint against the Bhola IPP gas plant in Bangladesh, citing coerced land acquisition, waterlogging, and a lack of meaningful consultation (CLEAN & Forum on ADB, 2022). What are the limitations of the PPM? Civil society organizations have raised several concerns: Difficult access and awareness for affected communities Delays and vague response timelines Requirement to first exhaust local remedies Lack of structural independence from AIIB Outcomes that may lack enforcement power What reforms are being demanded? Forumnetwork call for the PPM to be: More independent from AIIB management Easier to access for marginalized communities More transparent, with timely responses Able to enforce remedies and monitor compliance Read - NGO Forum on ADB’s Comments on the AIIB Project-affected People's Mechanism (PPM) Civil Society Open Letter to IAMNet - A Call to Defend the Independence of IAMs NGO Forum on ADB Joint Submission, AIIB ESF Review Phase 2 NGO Forum on ADB, AIIB ESF Review Phase 1 Input Asian Infrastructure Investment Bank’s (AIIB) Paper on the Accountability Framework

Discover the “Seven Cardinal Sins” of ADB through field publications and civil society voices, revealing gaps in safeguards, energy policy, and accountability. ADB Annual Meeting 2026 NGO Forum on ADB is participating in the 59th Annual Meeting of the Asian Development Bank (ADB) in Samarkand, Uzbekistan, to push for stronger accountability and people-centered development. Forum network will surface real experiences from communities to expose gaps in safeguards implementation and accountability systems, while calling for concrete reforms that ensure projects do not harm people or the environment. It will also challenge ADB’s current energy direction by advocating for a truly just transition aligned with climate goals—one that moves away from harmful investments and puts communities first. Through these discussions, Forum aims to amplify civil society voices and push ADB to deliver development that is fair, inclusive, and accountable to the people it is meant to serve. Seven Reflections – A Curated Digital Series Seven recurring failures, unfolding across safeguards and energy policies, quietly challenge the Asian Development Bank’s promise to “Do No Harm.” From what remains unseen to who remains unheard, these “Seven Cardinal Sins” reveal patterns that shape how development is experienced on the ground. Step into these stories and read the short reflections of members and allies of NGO Forum on ADB—voices that bring clarity, urgency, and a human face to what is too often left unspoken. Read the Reflections Advancing ADB’s Safeguards and Accountability This session will explore key gaps in safeguard implementation, assess how the ESF and Accountability Mechanism respond, and examine governance reforms needed to strengthen accountability. - May 3 (Sunday) | 11:00 AM – 12:30 PM (UZT) - ADB’s Commitment to a Just Transition and Paris Alignment This session will examine ADB’s energy reforms and climate finance trends, including the role of governance in shaping climate strategies and key gaps in advancing a just transition. - May 3 (Sunday) | 2:30 PM – 4:00 PM (UZT) - Fridays from the Field In the lead-up to ADB's 2026 Annual Meeting in Samarkand, Fridays from the Field set out to bring something often missing from official narratives into clear view: the lived realities of communities affected by ADB-funded projects. Now captured in a series of publications, these stories speak of delayed disclosures, rushed consultations, fear in raising concerns, and grievance systems that fall short when they are needed most. More than documentation, these pieces trace the deeper patterns behind these experiences—revealing how gaps in safeguards, accountability, and oversight continue to shape outcomes on the ground. Together, the publications stand as both record and reminder: that development is not measured by commitments alone, but by the lives it touches and the harms it must prevent. Download Watch the Sessions Forum Led Sessions Publications Debt, Delays, Dependencies: Why Public Banks Should Not Support Nuclear Power Urgewald & Ecodefense The world does not need new nuclear power. Yet institutions like the World Bank, the ADB, and other development banks are stubbornly marching towards an economic disaster that creates toxic waste and exacerbates the climate crisis by redirecting scarce resources away from technologies that have long proven themselves cheaper, faster, cleaner, and more effective. Download Partners in gas: How the ADB’s investment in Clifford Capital continues to support fossil gas in Asia Recourse, Trend Asia, NGO Forum on ADB, and CLEAN - Coastal Livelihood and Environmental Action Network This publication, “Partners in Gas: How ADB’s Investments in Clifford Capital Continue to Support Fossil Gas in Asia,” examines how the ADB financial intermediary lending can indirectly support fossil fuel expansion. Using the case of Clifford Capital, it highlights how opaque subproject disclosure, securitisation structures, and indirect financing pathways may allow continued investment in fossil gas projects despite ADB’s climate commitments. Download Who Pays for Energy Transition? The briefing argues that the “clean energy” transition still harms communities because it depends on critical minerals mining, which often causes displacement, pollution, and rights violations in the Global South. Framed as ADB’s “Seven Cardinal Sins,” these issues show systemic problems. The paper calls for a just, transparent, and community-led energy transition. Download Read the Forum Statement to ADB At the 59th Annual Meeting of the Asian Development Bank (ADB) in Samarkand, Uzbekistan, discussions take place amid rising global uncertainty. The ongoing global conflict in the Middle East, which began on February 28, 2026, has disrupted the existing world economic order, sending ripple effects to supply and value chains across the world. Asia and the Pacific have been hit severely and are facing intensified economic pressures, compounded by climate risks. In this context, civil society perspectives from across the region highlight the importance of carefully considering the embedded risks of current policy directions, project operations, and financing approaches. This moment is a critical juncture in Asia’s development trajectory. ADB must make prudent and far-sighted strategic decisions with its financing in order not to derail the region from meeting its SDG targets and Paris Alignment goals. This is not the time to embed the region into imported fossil fuel supply chains, and experiment with high-risk energy solutions such as Nuclear and Critical Minerals extractivism, both sectors that severely threaten the ADB's performance-based Safeguards standards. The Bank must prioritise basic development needs: poverty alleviation, public health, human rights, food security, water and sanitation, and climate change over large-scale commercial project interests. Global Economic and Geopolitical Context The genocide in Gaza, and the armed conflict-related deaths in Sudan, Yemen, Lebanon, Iran, and others, all illustrate the failure of the international system to protect Human Rights. To this end, ADB, as a multilateral development partner committed to sustainable development in Asia, must hold the line in upholding Human Rights in all of its operations. Consequently, transport disruptions of energy resources in the global economic system have led the International Monetary Fund (IMF) and the World Bank to issue warnings that emerging markets and developing nations will be hit hardest by rising energy costs and supply chain disruptions. Growth forecasts for developing economies have been revised down, inflation expectations have risen, and vulnerable nations are grappling with tighter budgets, higher debt burdens, and unprecedented food supply concerns. In this context, even a sustained 10% increase in oil prices could raise global inflation by 0.4 percentage points and reduce global output by 0.1–0.2%, further tightening the already constrained fiscal space of developing countries, according to the International Monetary Fund (2026). Further, ADB’s Asia Outlook projected that if the war persisted through the third quarter of the year, developing countries would experience a 4.7% decline in growth. Simultaneously, the International Energy Agency has reported that this conflict has caused the largest oil supply disruption on record, driving crude prices above $100 per barrel. Additionally, UN Trade and Development statistics show that rising interest payments have reduced government revenue available for other public expenditures in 99 developing countries between 2018 and 2024. Implications for Developing Member Countries Farmers across Asia are queuing for hours, carrying their irrigation pumps, in search of a drop of diesel. Their woes are compounded by a sweeping fertiliser shortage, which is likely to prove ominous for the next harvest. All this is driving rising food prices and panic among urban and rural communities. Due to oil supply shortfalls, educational institutions, offices, factories, and markets are all closing down early and reducing working hours to manage energy supply needs, leading to loss of wages and depreciating household incomes. Additionally, the reactive push for further fossil fuel supply procurement is contributing to the climate crisis, as each new fossil fuel project, justified as “energy security”, deepens import dependence, heightens the risk of stranded assets, and pushes countries further from a just transition and their Paris targets. In this ADB AGM, ongoing dialogue with civil society is vital, not optional. Independent civil society voices, such as the Forum and its allies, are mandated to speak truth to power at the ADB. Our goal is to assert to the decision makers of ADB that all bank operations must focus on protecting people’s livelihoods, food security, and access to critical social services such as health and education. Thus, ADB operations must be grounded in the Sustainable Development Goals (SDGs) and internationally ratified human rights conventions, including core ILO standards. We are urging the ADB to rethink and curtail its privatisation agenda and prioritize the public interest amid this turbulent time. The Forum in this AGM calls into question the fundamental objectives of the ADB: Who benefits from ADB's projects and who bears the losses? Who bears the heaviest burden of risk, and who accumulates wealth risk-free? Read the Statement ADB's Seven Cardinal Sins Development, at its best, promises progress without harm—a careful balance between growth and responsibility. The Asian Development Bank (ADB) has long embraced this vision, grounding its work in safeguards meant to protect people, communities, and the environment. Yet across projects and policies, a different story often emerges—one shaped by silences, gaps, and missed accountabilities. This page traces two parallel narratives through what we call the “Seven Cardinal Sins.” One set reflects the fractures within ADB’s safeguards and accountability systems—where transparency falters, consultations exclude, and remedies remain out of reach. The other turns to ADB’s energy and climate agenda, where commitments to a just and sustainable transition are tested by practices that risk leaving communities behind. Together, these “sins” are not merely a list of failures, but a pattern—one that reveals how structural weaknesses in governance and oversight can erode even the strongest principles, including the promise to “Do No Harm.” They invite us to look closer, to question deeper, and to imagine what accountability could truly mean. As you explore this page, we invite you to read the short reflections of members and allies of the NGO Forum on ADB—voices grounded in lived experience, bearing witness to the impacts of development, and calling for change that is not only promised, but realized. Because when accountability fails, it is not policies that bear the cost—but people, communities, and futures that cannot be undone. 1 Reflections Betrayal Nazareth Del Pilar | NGO Forum on ADB I believe that the cardinal sins of the ADB are persistent and have been sharpened by the current war in West Asia and broader tensions involving the West. In times of crisis, neoliberal institutions fall back on protecting markets and profits over people, with a clear form of betrayal where climate commitments and the “Do No Harm” principle are sidelined. The disruption in the Strait of Hormuz has driven up fuel prices and exposed Asia’s dependence on fossil fuels, yet instead of using this as a turning point for renewables, the ADB frames it as an “energy security” issue to justify continued support for fossil fuels and costly technologies. This approach is even reinforced in policy. The 2025 Energy Policy Review failed to close loopholes and instead expanded support for nuclear energy and critical minerals mining, with no real commitment to move away from fossil fuels. This reflects both betrayal and oversight failure, as weak accountability sustains these contradictions, while the ADB’s technology-agnostic stance allows it to appear ‘Paris-aligned’ even as it deepens reliance on extractive and carbon-heavy systems. 2 Accountability Gap Marjorie Pamintuan | Recourse The ADB insisted that fossil gas is a transition fuel during the mid-term review of its Energy Policy. Despite evidence saying otherwise, the bank still kept its doors open to fossil gas through direct investments and opaque financial intermediary projects. This Annual Meeting happens in the midst of the ongoing wars in the Middle East which again presents massive evidence that fossil gas is expensive, unreliable and impedes the just transition to renewable energy. Ordinary people suffer and literally pay the price of the resulting economic shocks. It is time that the ADB reflect. Do better by shutting direct and indirect financial flows to fossil gas, and double down on its support for just renewable energy transition in developing countries to avoid future fossil fuel crises. 3 Impunity / Lack of Remedy Yuki Tanabe | Japan Center for a Sustainable Environment and Society (JACSES) Fifteen years after the Fukushima nuclear disaster, its impacts are far from over. Around 300 square kilometers remain under evacuation, and more than 20,000 people are still unable to return to their homes. What was once a place of everyday life has become a long-term exclusion zone. Unlike typical nuclear plants that are decommissioned decades after shutdown, Fukushima presents a far more complex reality. With melted nuclear fuel still inside the reactors, the decommissioning process is expected to take centuries—stretching the consequences of a single disaster across generations. This raises difficult but necessary questions for the region. Can countries in Asia truly prepare for emergencies of this scale? And is it possible to ensure meaningful consultation and protection for the vast number of people who would be affected? Daniel Willis | Recourse At the Annual Meeting, as in years gone by, affected communities and CSOs will bring many examples of how ADB-financed projects have caused devastating social and environmental harms. Many communities have brought official complaints to the ADB's Accountability Mechanism to seek justice. However, research by Accountability Counsel shows that remedial action has been taken in only 3% of closed cases. One problem is that many complaints are deemed ineligible due to the onerous requirements of the Mechanism's policy. There is an opportunity to change this, though, with the ongoing review of that policy, which is sure to be a key topic of debate in Samarkand. ADB should listen to the testimonies of harm from affected communities, and to their demands for a more accessible Accountability Mechanism that investigates complaints and delivers on remedy. 4 Gender inequality / exclusion of women and vulnerable groups Titi Soentoro | Aksi! for Gender, Social, and Ecological Justice ADB speaks of building a “prosperous, inclusive, resilient, and sustainable” Asia-Pacific, yet the reality on the ground often reflects a gap between commitment and practice. Development approaches frequently remain top-down, prioritizing corporate interests while communities bear environmental and social costs, with women and vulnerable groups disproportionately affected and often excluded from meaningful consultation. These challenges underscore the need for stronger accountability—ensuring genuine participation, especially of women, and establishing grievance mechanisms that effectively address gender-related impacts. Ultimately, a truly just and inclusive approach requires the ADB to move beyond policy commitments and take responsibility for the indirect, long-term, and cumulative harm linked to its projects. 5 Lack of meaningful participation Chinara Aitbaeva | Nash Vek Public Foundation ADB CAREC Program aims to improve connectivity and boost economic growth across Central Asia, but it also raises important questions about who truly benefits. While large projects in infrastructure, energy, and trade are meant to support development, they often follow a top-down approach that may overlook the needs of local communities. Concerns remain about transparency, meaningful participation, and whether people affected by these projects are truly heard. As CAREC moves forward, it is important to ensure that development is not only about building roads and markets, but also about protecting communities, promoting fairness, and making sure that no one is left behind. 6 Delayed justice Indira Shreesh | Indigenous Women's Legal Awareness Group (INWOLAG) The experience of the Tanahu Hydropower Project reflects what can be described as the seven cardinal sins of the ADB: first, the persistent gap between policy and practice, where strong safeguards, particularly Principle 8 and Principle 9 on Indigenous Peoples and customary land rights, remains largely unimplemented; second, the failure to recognize customary and Indigenous land rights, especially for non-titled lands; third, the weak and procedural approach to Free, Prior, and Informed Consent (FPIC), reducing it to consultation rather than genuine consent; fourth, inadequate and unjust compensation systems that fail to restore livelihoods; fifth, the lack of transparency and accountability in land acquisition and project implementation; sixth, delayed grievance redress and weak enforcement of accountability mechanisms, where justice is delayed and the ignoring of justice must be treated as punishable failures, and must also ensure fair and adequate compensation to affected communities; and seventh, a broader pattern of development prioritization over human rights, where infrastructure goals overshadow the dignity, identity, and rights of Indigenous Peoples. Together, these systemic failures risk turning safeguard policies into symbolic commitments rather than instruments of justice. 7 Procedural (not meaningful) consultation Hussain Jarwar | Indus Consortium Despite having clear safeguard standards, the experience on the ground often tells a different story. Consultations carried out by the Asian Development Bank have frequently remained procedural, falling short of the meaningful engagement that communities expect and deserve. Many affected groups continue to report exclusion from genuine dialogue, often justified by security or administrative constraints. This raises deeper concerns about how policies are translated into practice, as direct and transparent engagement with impacted populations remains limited. Over time, this gap not only restricts communities from fully voicing their concerns but also contributes to growing mistrust toward development institutions, highlighting the need for more inclusive and accountable approaches.