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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

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 Civil society demands ADB to strengthen environmental and social safeguards ahead of R-Paper release Read All Collective Civil Society Statement on ESF Draft: Calling for an Overhaul and immediate redrafting Read All Civil society recommendations on the ADB Safeguards Policy Statement (SPS) consultation process Read All NGO Forum on ADB Comments: Safeguard Compliance and Accountability Mechanism Framework Read All PH CSO Statement re: ADB’s Draft Environmental and Social Framework (ESF) Read All Request for Extension of Deadline for Submission of Written Comments on ADB's Draft ESF Read All Joint civil society statement for a robust, rights-based and just safeguards policy at the ADB Read All ADB Safeguard Spotlight The Story of ADB Safeguards Related Documents ADB Project Tracker COVID19 Loan Tracker ADB Documents This section compiles key documents utilized during the NGO Forum on ADB's campaign to strengthen the ADB safeguard policies. It includes ADB papers released during the campaign timeline. Publication This section features key publications produced by NGO Forum on ADB and its network during the ADB Safeguards Campaign. Advocacy Archives This section houses a curated collection of historical documents related to NGO Forum on ADB's Safeguards Campaign.

Follow the AIIB energy campaign led by NGO Forum on ADB and allies, spotlighting civil society efforts to push the Asian Infrastructure Investment Bank away from fossil fuels and toward just, community-centered renewable energy transitions. ASIAN DEVELOPMENT BANK (ADB) Project Monitoring Energy Campaign Project-affected People's Mechanism (PPM) AIIB Annual Meeting PROYEKTO MONITORING The Forum network maintains that the Asian Infrastructure Investment Bank’s (AIIB) ongoing support for fossil gas projects locks member countries into carbon-intensive energy systems and exposes them to global market volatility—an approach that is environmentally and economically irresponsible given AIIB’s limited resources and climate commitments (Urgewald, 2023; CLEAN & Forum on ADB, 2022). The network is also concerned that AIIB may increasingly shift toward high-risk sectors like large hydropower, waste-to-energy incineration, and geothermal, which have significant environmental and social costs. In particular, large hydro projects have a long record of displacing communities, damaging ecosystems, and generating conflict over land and water (International Rivers, 2021). The Forum calls for stricter financing criteria and meaningful consultation to ensure AIIB aligns with the goals of a just, community-centered energy transition. Read - Unpacking ADB and AIIB’s false narrative in COP29 Digital infrastructure for whom? Unpacking ADB and AIIB’s digital push AIIB Climate Advocacy Letter Critical Concerns on the Occasion of AIIB's Annual Meeting 2023 Open Statement on Collective Concerns Re: AIIB’s 2022 Energy Sector Strategy Update Re: Virtual Consultations Hosted by AIIB on the Energy Sector Strategy Update AIIB asked to go green, turn back on fossil fuels AIIB’s Extended Deadline for Public Input on the Energy Sector Strategy Update Collective Statement For the Energy Sector Strategy Update Collective Call for a New Forward-Looking AIIB Energy Sector Strategy Joint Submission by NGO Forum on ADB & Urgewald on the AIIB Environmental and Social Framework

Mga Gabay na Aklat RESOURCES Bankwatch | Taunang Ulat | Mga Espesyal na Lathalain | Maikling Proyekto Pera mula sa Europa Mekanismo ng Pananagutan ng ADB Mga Mapanganib na Pagkagambala

ADB Energy Policy Review Scorecard Why This Matters This year marks a decade since the Paris Agreement — yet the Asian Development Bank (ADB) still falls short of the 1.5°C goal. ADB’s Energy Policy Review proposes dangerous rollbacks, including: Reviving extractive industries Lifting the ban on nuclear energy investments Promoting co-firing and other false “transition” technologies Keeping loopholes for coal and gas As the world nears a climate tipping point, ADB continues to lag behind its own claims as a “climate bank.” What’s ADB’s Score? That’s for you to decide. Each Forum network member and ally can grade ADB’s Energy Policy Review process and proposed revisions based on their alignment with real climate action — or lack thereof. How to Participate Download the Score you give ADB in the Scorecard drive . Grade ADB’s performance on its Energy Policy Review and proposed revisions. Post your score publicly with any of these hashtags - #ADBFailingDClimateTest #ADBFossilFail #ADBClimateScore Tag ADB Facebook: Asian Development Bank X (Twitter): @ADB_HQ LinkedIn: Asian Development Bank Explain your score in one line. Example: “We give ADB a failing grade for pushing fossil fuels.” Let us know if your organization is joining so we can amplify your post. If you don’t have social media, NGO Forum on ADB can post your score on your behalf, with full credit to your organization. Need Help? If your schedule is tight, fill out this short form and we’ll prepare and post your materials for you — all you have to do is share. You can also check the Scorecard meanings below - Here is an example -

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 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.

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).

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

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 01 ESF December 2024 02 ESF Policy Paper 03 Environmental and Social Framework (September 2024 - Revised Draft) 04 ESF Consultation Draft 05 Safeguard Policy Statement Review and Update Policy Architecture Study 06 Safeguard Policy Statement Review and Update Stakeholder Engagement Plan 07 Safeguard Policy Statement Review and Update Stakeholder Engagement Plan (Version 2) 08 Access Information Policy 2018 ADB Safeguard Spotlight The Story of ADB Safeguards Related Documents ADB Project Tracker COVID19 Loan Tracker 2010 Forum’s Comments on the Operations Manual of the new Safeguard Policy Statement (February 2010) 2009 OM Language Recommendations of the Forum (31 July 2009) Comments on the Forum on R-Paper of the Safeguard Policy Statement (14 July 2009) Detailed recommendations for the improvement of the SPS R-paper (15 July 2009) Safeguard Policy Statement: updated Safeguards (June 2009) Comments on the 2nd draft Safeguard Policy Statement United Nations Educational, Scientific, and Cultural Organization (UNESCO), 8 January 200 2008 Comments on the 2nd draft Safeguard Policy Statement US Department of Treasury, 17 December 2008 US Department of Treasury, 7 December 2008 Gender Action, 5 December 2008 Public Services International, 4 December 2008 International Accountability Project, 4 December 2008 Consolidated IP-SPU workshop participants, 4 December 2008 Forest Peoples Programme, 4 December 2008 NADI, 4 December 2008 World Resources Institute, 4 December 2008 Bank Information Centre, 4 December 2008 NGO Forum on ADB, 4 December 2008 NGO Forum on ADB’s initial comments on the draft Safeguards operations manual, 4 December 2008 Centre for Environmental Justice, 4 December 2008 Environmental Law Alliance Worldwide (E-Law), 3 December 2008 Environmental Defense Fund, 2 December 2008 Central Asia and Caucasus NGOs, 27 November 2008 International Network on Displacement and Resettlement, 20 November 2008 Japan Center for Sustainable Environment and Society (JACSES), 13 November 2008 ADB’s response to Forum’s proposed agenda for the second round SPU consultation, 22 August 2008 Forum’s proposed agenda for the second round SPU consultation, 25 July 2008 Forum’s response to ADB’s consultation plan, 4 July 2008 Safeguards Down the Drain, Hemantha Withanage ADB Environmental Safeguards in Reverse Gear!, Avilash Raoul Country Safeguard Systems approach at the ADB, Jennifer Kalafut Involuntary Resettlement & the Asian Development Bank, Joanna Levitt Safeguarding Indigenous Peoples’ Rights, Rowena Soriaga Forum’s comments on the Draft SPS, 28 April 2008 BIC’s Comments on the Draft SPS, 30 March 2008 E-Law’s Comments on Draft SPS, 21 March 2008 Downing and Scudder Expert Opinion on ADB SPU, 20 March 2008 ADB’s response to Forum’s Call for Revision of SPS, 7 March 2008 Burmese Civil Society Groups’ Letter to the ADB on SPU, 4 March 2008 Vietnam NGOs’ letter on SPU consultation, 25 February 2008 IAITPTF’s Letter to the ADB on the Draft Safeguard Policy Statement, 22 February 2008 IAP’s Comments on the Draft Safeguard Policy Statement, 19 February 2008 German Economic Minister Letter on the ongoing SPU, 11 February 2008 Forum’s letter to ADB President calling for the revision of the SPS draft, 7 February 2008 Forum’s letter to SPU Team calling for the revision of the SPS draft, 7 February 2008 2007 Act Now! Demand for Greater Safeguards, 23 November 2007 ADB’s Country Safeguards System, November 2007 ADB’s response to Forum’s letters on SPU process, 6 November 2007 Forum’s letter to ADB regarding the SPU Process, 25 October 2007 Forum’s letter to ADB regarding the SPU Process, 24 October 2007 Consultation Draft of the Safeguard Policy Statement, October 2007 Forest People’s Programme’s comments on the OED Special Evaluation Study on the Indigenous Peoples Policy In Search of Middle Ground: Indigenous Peoples, Collective Representation and the Right to Free, Prior and Informed Consent, Annex to FPP’s comment to the OED Special Evaluation Study on IP Policy, by Marcus Colchester and Fergus MacKay, Forest Peoples Programme, August 2004 A Call to Safeguard Equitable and Sustainable Development in Asia: Collective statement by NGO Forum on ADB regarding the ADB Safeguard Policy Update, March 2007 2006 Comparative Matrix – Environment Policy Weekend Standards Yes to Accountability, 20 April 2006 Open Letter to the ADB president on the Safeguard Policy Update, 16 March 2006 Comparative Matrix – Indigenous Peoples Policy Comparative Matrix – Involuntary Resettlement Policy ADB Resettlement Policy Comparative Matrix, International Accountability Project, November 2006 Snapshots of ADB Disasters Development Debacles Civil Society Says, “No to 2005 ADB Discussion Note- October 2005 ADB Response by Mr. Albab Akanda, Team Leader- 28 September 2005 Civil Society Organization’s letter to ADB President Haruhiko Kuroda – 22 July 2005 Board Approval for the Consolidated Review of the ADB Safeguards Policies – July 2005 Window Dressing for Business? The Asian Development Bank Safeguard Policy Implementation Review by Grace Mang ADB and the Environment (NGO FORUM ON ADB Publication) Indigenous people and the ADB (NGO FORUM ON ADB Publication ) ADB Documents ADB Response by SPU Team on discussion note (28 September 2005) Discussion Note: Safeguard Policy Statement (October 2005) Consultation Draft of the Safeguard Policy Statement (October 2007) ADB’s response to Forum’s Call for Revision of SPS (7 March 2008) ADB’s response to Forum’s proposed agenda for the second round SPU consultation (22 August 2008) Preliminary Draft Operations Manual Section, Draft Safeguards Review Procedures (3 October 2008) ADB SPU: Report on Stakeholder Consultations (Comments-response matrix) (8 October 2008) 2nd Draft Safeguard Policy Statement (October 2008) Working Paper: Safeguard Policy Statement (January 2009) Safeguard Policy Statement (June 2009) Statement (October 2007) Safeguards Operations Manual (January 2010) Older Safeguards Documents

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.

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