mostly the same.5 The revised SEP, however, does not include a footnote that includes a longer list of characteristics from which vulnerability can stem.6 SEPs should all refer to the Bank’s definition of “vulnerability” to verify that they are including relevant “disadvantaged or vulnerable” groups as stakeholders. Furthermore, there is generally a lack of consistency of the groups listed as “vulnerable,” even within the revised SEP itself. A section of the revised SEP titled: “Proposed strategies for incorporating the views of vulnerable groups” only includes three of the eight groups named in the section with a list of “disadvantaged or vulnerable individuals or groups.” Women and pregnant women are not listed as “disadvantaged or vulnerable,” but they are listed under the “proposed strategies” section. Four vulnerable groups listed in the Directive are not listed in either the original or revised SEPs: LGBTQI individuals, Indigenous Peoples, those who might be adversely affected due to their civic status, and those who are economically disadvantaged.7 It is important that SEPs identify and maintain a consistent list of marginalized groups so that it is clear that all potentially marginalized groups have been assessed and that those groups will continue to be considered in each component of the engagement process. The original LCERP SEP says that a community engagement exercise would be carried out to confirm the groups that are listed, but neither SEP includes a description of this exercise. Furthermore, there is no explanation for why the list of “disadvantaged or vulnerable individuals or groups” in the revised SEP is different than that in the original SEP. Some groups were added in the revised SEP, such as ZOGOS (war affected children and persons) and “people living on the streets,” and some groups were removed, such as ethnic and religious minorities, drug addicts, 5 Per the original SEP: “The vulnerability may stem from person’s origin, gender, age, health condition, economic deficiency and financial insecurity, disadvantaged status in the community.” The original SEP also includes “dependence on other individuals or natural resources” in the listed characteristics. See Chisaka, “SEP - Liberia COVID-19 Project,” 8; Srivastava, “Revised SEP Liberia COVID-19 Project,” 27. 6 The revised SEP lacks a footnote that provides a broader and more encompassing definition than those in the main text. The footnote in the original SEP states: “Vulnerable status may stem from an individual’s or group’s race, national, ethnic or social origin, color, gender, language, religion, political or other opinion, property, age, culture, literacy, sickness, physical or mental disability, poverty or economic disadvantage, and dependence on unique natural resources.” See Chisaka, “SEP - Liberia COVID-19 Project,” 8. 7 For characteristics listed in the original and revised SEPs, see: Chisaka, “SEP - Liberia COVID-19 Project,” 6-8; Srivastava, “Revised SEP - Liberia COVID-19 Project,” 25-27. For characteristics listed in The Directive, see: “The Directive,” 1. BANK INFORMATION CENTER | MAR 2021 and internally displaced people. While it is not required, the lack of an explanation for why groups were removed from the list of “disadvantaged or vulnerable individuals or groups” makes it difficult to ascertain if they were removed as a result of a verification exercise or due to negligence. B. Information Disclosure and Accessibility 1. Languages and formats for project information disclosure → The revised SEP updates the original by pointing to disclosing information in local languages through multiple forms of communication See section B.1 in the main text for more information about relevant ESF requirements Borrowers must disclose project information in “relevant local languages” and in formats that are culturally appropriate and accessible, such that they take into account specific needs “of groups that may be differentially or disproportionately affected by the project for reasons stemming from disability, literacy, gender, mobility, and differences in language.”8 According to guidance on ESS10, drafts of the SEPs should be “made available to stakeholders in accessible formats and through channels that are appropriate for them.”9 While the original LCERP SEP simply indicated that stakeholders should receive information that “timely, relevant, understandable and accessible” the revised SEP includes a table titled “Strategy for Information Disclosure for COVID-19” which provides a more detailed plan for what information will be disclosed when and by what means than the original SEP.10 Neither SEP specifies what languages or formats will be used to make information understandable and accessible, and therefore these types of details are more likely to be overlooked. Furthermore, neither SEP addresses the need for information to be disclosed in a “culturally appropriate” manner so that stakeholders feel comfortable engaging with the project information. The revised SEP says that the project will take steps to incorporate the views of persons with disabilities by providing information “in accessible formats” and through “multiple forms of communication.” Again, the revised SEP does not offer examples of 8 See 3ciii under ESS10 in Annex 1; “Environmental and Social Framework,” 99, par. 20. 9 See 3n under ESS10 in Annex 1; “Guidance Note: ESS10,” 5, GN13.3. 10 Chisaka, “SEP - Liberia COVID-19 Project,” 1; Srivastava, “Revised SEP - Liberia COVID-19 Project,” 33. 43