Bank staff must review projects’ environmental and social assessments to verify that they identify groups and individuals “affected by the project that may be disadvantaged or vulnerable.”17 They must also verify that SEPs have identified “disadvantaged or vulnerable individuals or groups” among project stakeholders.18 Definitions of “vulnerability” and “disadvantaged or vulnerable groups” in the examined SEPs Ten of the 11 SEPs analyzed provide definitions of “vulnerability” or “vulnerable status” that alludes to the characteristics listed in the definition of “vulnerable” from the Directive (The Gambia does not provide a definition: it simply includes a header for “vulnerable groups’’ and a list of stakeholders that fall into that category). None of them, however, include all of the characteristics that the Directive says can lead to vulnerability. Furthermore, none of the analyzed SEPs has a list of “disadvantaged or vulnerable groups” that matches the list found in the Directive and, as stated in A.1, do not provide explanations for why groups were included or not. Table 1 shows which of the analyzed SEPs included a reference to groups listed in the Directive under stakeholders that are considered “disadvantaged or vulnerable” for the project. Only “people with disabilities” and “the elderly” are listed in every SEP. Only five of the SEPs list children or children-headed households. Three SEPs use a term to describe sexual orientation or gender identity as a reason a group is vulnerable: the Nepal SEP lists LGBTI people; Uganda’s lists “sexual minorities;” and Cambodia’s lists the term “SOGI” (sexual orientation and gender identity). Though groups that “depend on unique natural resources” may experience certain vulnerabilities or barriers to project benefits, none of the SEPs mention them. Bank staff are bound by the definition and requirements listed Directive. The exact nature and context of the project might make some groups more vulnerable to harm than others, but it is important that each project reference the same definition of “vulnerable” that comes from the Directive so that it is clear all potentially marginalized groups have been assessed. orientation; gender identity; economic disadvantages; indigenous status; dependence on unique natural resources. 17 See 2a under The Directive in Annex 1; “The Directive,” 2. See also “Guidance Note: ESS10,” 4, GN10.1(a). 18 See 2b under The Directive in Annex 1; “The Directive,” 3. BANK INFORMATION CENTER | MAR 2021 B. INFORMATION DISCLOSURE AND ACCESSIBILITY 1. Languages and formats for project information disclosure Relevant ESF requirements for SEP and project information disclosure The Bank must, according to the ESP, require Borrowers “to provide sufficient information about the potential risks and impacts of the project” for consultations with stakeholders.19 The information must be in accessible forms and understandable languages so that stakeholders can “provide meaningful input into project design and mitigation measures”.20 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.”21 While Borrowers are not required to develop a standalone Stakeholder Engagement Plan (SEP) for every project, they are required to develop and implement the elements of an SEP for every project and include them in the Environmental and Social Commitment Plan if a stand-alone is not necessary.22 Still, they must engage with stakeholders and provide them with appropriate information throughout the project life cycle.23 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.”24 Language and accessible formats for information disclosure in the examined SEPs Despite these language requirements and guidance, seven of the 11 SEPs have not been disclosed on the World Bank’s website in relevant local languages. As shown in Table 2, the Guatemala and El Salvador projects are the only ones that disclosed SEPs in non-English official languages of their countries.25 19 See 1c under ESP in Annex 1; “Environmental and Social Framework,” 9, par. 50. 20 Ibid. 21 See 3ciii under ESS10 in Annex 1; “Environmental and Social Framework,” 99, par. 20. 22 See 3bii under ESS10 in Annex 1; “Environmental and Social Framework,” 99, par. 13. 23 See 3civ under ESS10 in Annex 1; “Environmental and Social Framework,” 100, par. 23. See also 2a under ESS1 in Annex 1; “Environmental and Social Framework,” 22, par. 51. 24 See 3n under ESS10 in Annex 1; “Guidance Note: ESS10,” 5, GN13.3. 25 A Spanish-language SEP for the Guatemala project was disclosed on the Bank’s website on October 22, 2020, six months after the English-language SEP was disclosed. See “Disclosure Date” on the document landing 7