substantial risk of corruption and lack of transparency. IFIS FAILED TO ENSURE A BASIC DEGREE OF IDB funds that were slated to go toward the purchase TRANSPARENCY AND PARTICIPATION of critical COVID-19 medical equipment were misspent. IDB announced an investigation into corruption, but meanwhile, the case paralyzed operations of the health agency for months in the midst of the pandemic.12 In Argentina, in a project for which the IDB redirected 490 million USD in infrastructure financing to COVID-19 response, the entire process for project approval took less than two months, raising serious doubts as to whether due diligence was conducted. Researchers note that “it is striking that the [social and environmental assessment] could have been published only three days after the public consultations were carried out, which would imply, in practice, that they only had two days to incorporate the suggestions and recommendations expressed in the consultations, if they actually incorporated the suggestions.”13 In a World Bank-financed health project in Morocco, a key social and environmental risk was the large amount of medical waste from COVID-19 testing, treatment, and protective equipment. While the Bank claimed to have consulted with civil society, no consultations were held with groups working on project-related issues of public health and safety. Project documents were also not available in Arabic. Importantly, there was no information on the protocol for COVID-19 medical waste, and this failure put health workers at risk. A survey of public hospital staff revealed significant dysfunction in the management of medical waste, including the lack of protection for staff.15 In India, the Asian Development Bank (ADB) and Asian Infrastructure Investment Bank (AIIB) supported a government life insurance program for doctors who died IFIs turned a blind eye as civil society and key stakeholders were left in the dark and left out. In an atmosphere where many governments were actively suppressing information about the pandemic and restricting freedom of the press and civic watchdog groups, IFIs failed to ensure a basic degree of transparency and participation.14 Not only did IFI-financed programs fail to consult with the public at large and with those most vulnerable to the pandemic, but in multiple cases they excluded health experts and medical associations, resulting in adverse impacts on health and safety as well as accountability. While governments argued that consultations with civil society were impossible given the lockdown, provisions could have been made for virtual consultations with key populations and civil society groups in an inclusive and accessible manner. of COVID-19 as part of their support for the pandemic response. Researchers, however, found that the program was insufficient and difficult to access, with people being denied eligibility and numbers that do not add up. Researchers point to an alarming lack of transparency and active suppression of information on the part of the government: “from the number of people infected by the virus, to the number of people who succumbed and the number of people who have been recipients of welfare schemes of the government and amount spent.” Neither ADB nor AIIB have published any monitoring reports at the time of writing.16 In Yemen, given the ongoing civil war, World Bank support for COVID-19 emergency response was channeled through the World Health Organization as a 26.9 million USD grant. While it should be noted that the use of a grant rather than a loan was critical for the Yemeni population, the project failed to meet its potential due to a lack of transparency and stakeholder engagement. In a survey of the Ministry of Health and relevant public entities such as the quarantine and isolation centers and the National Coronavirus Committee, 89% responded that there was no engagement of any kind in planning, implementation, 12 Palacios, D, “Estudio de consultoría realizado por encargo del CEDLA para realizar un análisis sobre los préstamos del BID en la Región: caso Bolivia referidos al COVID-19”, CEDLA, May 14, 2021, 13 “DFIs financing in Argentina during the pandemic: COVID-19 projects and transparency shortcomings”, Fundación Ambiente y Recursos Naturales, 2021, https://farn.org.ar/wp-content/ uploads/2021/11/DOC_COVID-PROJECTS-V3-1.pdf. 14 See e.g. “Unhealthy Silence: Development banks’ inaction on retaliation during COVID-19”, Coalition for Human Rights in Development, Article 19 and Ifex, July 2021, https:// rightsindevelopment.org/unhealthy-silence/. or monitoring and 66 % stated that there is no access to 15 “A report on the management of medical and pharmaceutical waste by hospitals in the Rabat-Sale Kenitra region as part of the World Bank-funded healthcare improvement project”, Association Talassemtane pour l’Environnement et le Développement and Arab Watch Coalition, January 2021 16 “Country Assessment Report COVID-19 recovery loans in India”, Growthwatch India, 2021 WHERE DID INTERNATIONAL FINANCIAL INSTITUTIONS’ COVID-19 FUNDING GO? 6

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