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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 Letter on ADB’s flawed July 22 CSO consultation Two decades in ADB’s ACEF: a race away from 1.5°c - NGO Forum on ADB Statement on the ADB Asia Clean Energy Forum 2025 Forum Network urgent concerns on ADB Energy Policy Review 2025 Forum Network Letter – Concerns on ADB CM2CET Value Chains Approach Unpacking ADB and AIIB’s false narrative in COP29 Re: Climate-Smart Mining for a New Climate Economy (Project 57273-001) Latest News Latest Events/Activities

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 WATCH Information Disclosure of Multilateral Development Banks in the New Era 6 May 2017 | Yokohama, Japan

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 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 Role of Private Sector and Financial Intermediaries in ADB’s Energy Sector Investments 3 May 2018 | Manila, Philippines 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. 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 The Asian Development Bank’s (ADB) Public Communications Policy (PCP) guides the ADB’s external relations when it comes to transparency and in its operations. The PCP, also known as the policy on information disclosure, intends to provide greater access to project information documents and related information. It ensures participation by project-affected people in the development intervention of the ADB in their respective communities. It mandates all project-related documents to be posted on the ADB’s website. Access to project-related information by local people allows them to participate actively and effectively in decision-making processes related to the development agenda of international financial institutions such as the ADB in their respective communities which could adversely affect the environment and disrupt their living conditions. Issues with the PCP Though it has been stating that it values transparency and is committed to increasing information disclosure, the ADB has fallen short on its commitment to respecting the rights of the people’s right to information. The PCP does not expressly recognize public access to information is a right. Experiences on the ground have shown that the Bank lacks both the political will and the resources to respect this right. Documents identified by the ADB as publicly available are only accessible through its website. This has prevented poor communities from getting project-related information since the internet facility remains a luxury for them. Civil society groups believe that this manifests the pro-business bias of the Bank’s disclosure policy. The PCP also provides a long list of exceptions. Not all exceptions identify the serious harm to a clearly and narrowly defined, and broadly accepted, an interest that is sought to be avoided by non-disclosure. Below are NGO forum on ADB's submission, communication, and other documents on its campaign on a just ADB PCP - 05 Apr 2018 | Joint Submission of NGO Forum on ADB and Both ENDS Comments on the 2nd draft of the Public Communications Policy 14 Jan 2018 | NGO Forum on ADB's Summary Comments on the PCP Review 28 Nov 2017 | NGO Forum on ADB Summary Comments (meeting with PCP Review Team) 16 Jul 2017 | NGO Forum on ADB Letter to the ongoing consultations related to the Review of the Public Communications Policy (PCP) 12 Jul 2017 | Summary of questions and comments during the country consultations 26 Mar 2017 | ADB's response to Forum's submission on PCP Review 23 Jul 2017 | ADB's response to Forum's Letter to the ongoing consultations related to the review of the PCP (dated 17 July 2017) 17 Aug 2017 | Comments of NGO Forum on ADB on the draft staff instructions 30 Nov 2016 | NGO Forum on ADB Submission on the Draft Public Communications Policy of the Asian Development Bank 10 May 2016 | Public Communications Policy Review 04 May 2011 | NGOs warn ‘safety valve’ may impede ADB’s small success in transparency 13 Jan 2011 | ADB Must Clinch the Opportunity for Bolder PCP Reforms 22 Sep 2010 | Letter to PCP Review Team 31 Jan 2010 | Practice What You Preach 31 Jan 2009 | Statistical highlights on the Asian Development Bank’s Public Communications Policy Implementation (August 2005 to February 2009)

Explore ADB’s Energy Investments in South Asia This interactive page offers a visual overview of the Asian Development Bank’s (ADB) energy investments across South Asia. How to use this dashboard? Click on any item—such as a country, safeguard category, or type of violation—to view detailed project information and related issues. Click the same item again to return to the full regional overview. Use the filters and visual tools to explore where and how safeguard breaches have occurred in ADB’s energy portfolio across South Asia. Safeguards Overview of ADB Energy Investments in South Asia Next

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

PAKISTAN BANGLADESH INDIA INDONESIA PHILIPPINES BANGLADESH BANGLADESH Source: Bangladesh: COVID-19 Active Response and Expenditure Support Program LATEST NEWS UPDATES 22 December 2022 Pakistan, ADB sign agreements worth $1.5bn for various projects 19 October 2021 Pakistan in deep economic crisis, needs $51.6 billion external financing over two year period 6 August 2021 ADB approves $500m loan to help Pakistan procure Covid-19 vaccines 10 June 2021 ADB approves $500m emergency loan for Pakistan

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

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.

Mga update sa COVID-19 COMMUNITY EMERGENCY FUND KABUUANG HALAGA NG SUPPORT NA NATANGGAP noong Agosto 20, 2020 $9,000.00 KABUUANG HALAGANG NABIGAY $4,500.00

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