In addition, according to the ESF Good Practice Note
“Addressing Sexual Exploitation and Abuse and
Sexual Harassment (SEA/SH) in Investment Project
Financing involving Major Civil Works,” “all projects
need to have a framework for properly handling SEA/
SH allegations.”63 A report from the Bank’s Global
Gender-Based Violence Task Force also indicates that
the GRMs for all Bank investment projects must have
“mechanisms to track complaints specifically linked
to SEA and GBV” incorporated into them.64 Survivors
that submit grievances about gender-based violence
(GBV), especially sexual exploitation and abuse
and sexual harassment (SEA/SH), may have “risks
of stigmatization, rejection and reprisals.”65 The
Good Practice Note explains that “SEA and SH are
manifestations of GBV,” which is “an umbrella term
for any harmful act that is perpetrated against a
person’s will and that is based on socially-ascribed
gender differences.”66
Equipping GRMs to handle GBV/SEA/SH in the
examined SEPs
Five of the examined SEPs — those of Liberia,
Philippines, Sri Lanka, Burkina Faso, and Nepal —
indicate that the GRMs used for the projects will
be equipped to handle GBV or GBV/SEA/SH. Table
5 shows, however, that these five projects use
different terminology to describe how they will equip
their GRMs to handle different forms of gender or
sexual violence. Three SEPs, those of Philippines,
Burkina Faso, and Nepal, state that their GRMs will
have procedures to handle “GBV” grievances.67 The
GRMs for both the Liberia and Sri Lanka projects
will be equipped to handle allegations of “GBV/SEA/
SH.”68 The Uganda and El Salvador SEPs indicate that
the Ministry of Health will make available resources
to report cases of “GBV/SEA” and violence against
children (VAC), but describe these resources as
63 See 6d under GPN in Annex 1; Grown et al., “Good Practice Note:
Addressing SEA/SH,” 44, par. 116. It is outside the scope of this report
to assess whether all or parts of these projects are considered major civil
works and whether the ESF Good Practice Note should be applied.
64 Sierra and Gupta, “Working Together to Prevent Sexual Exploitation
and Abuse,” 41.
65 See 6c under GPN in Annex 1; Grown et al., “Good Practice Note:
Addressing SEA/SH,” 36, par. 87.
66 See 6a under GPN in Annex 1; Grown et al., “Good Practice Note:
Addressing SEA/SH,” 5, par. 12; 6, par. 16.
67 The Philippines SEP does not provide information specifically about
how the GRM will be equipped to handle GBV complaints but says that a
revised SEP will have further details. The Burkina Faso SEP indicates that
the GRM will have “specific procedures in place for addressing GBV” and
that the project will consider establishing a separate GRM to handle GBV
complaints. The Nepal SEP says that the GRM for the project “will be
used for addressing GBV-related issues.” See: Demombynes, “SEP - Philippines COVID-19 Project,” 10; Besarabic Bennett, “SEP- Burkina Faso
COVID-19 Project,” 13; Bhattarai, “SEP - Nepal COVID-19 Project,” 11.
68 Chisaka, “SEP - Liberia COVID-19 Project,” 11-12; Kak, “SEP - Sri
Lanka COVID-19 Project,” 15-16.
BANK INFORMATION CENTER | MAR 2021
hotlines separate from a GRM.69
Though only five projects indicate that their GRMs
will specially handle GBV/SEA/SH complaints, all
11 projects’ ESRSs point to the fact that there is a
potential risk of some combination of GBV/SEA/
SH and VAC. Table 5 shows, however, that the risk
comes up in different parts of the ESRSs in different
ways. Four of the projects’ ESRSs mention the risk
under “Social Risk Rating” in the “Environmental and
Social Risk Classification” section as well as a risk in
connection to “ESS1 Assessment and Management
of Environmental and Social Risks and Impacts,” as
something that could happen to women and children
under self-isolation. Six projects mention the risks as
being associated with ESS4 Community Health and
Safety, and refer to the potential for GBV/SEA/SH to
occur in workplaces. The Bangladesh project brings
up GBV as a risk in the context of “ESS2 Labor and
Working Conditions.”70 Furthermore, some ESRSs list
“GBV/SEA/SH,” some just list “GBV/SEA,” and others
list “SEA/SH.”
In addition to the irregularities across the 11 projects,
different documents prepared for the same project
do not refer to potential risks of sexual and genderbased violence in a consistent manner. For example,
the Burkina Faso ESRS indicates that SEA/SH are
risks, but the SEP only describes the project’s GRM
being equipped to handle GBV complaints.71 Since
the mechanisms for avoiding the risks and handling
the grievances of each of these issues may differ, it
is important that terminology is used precisely and
consistently.
It is outside the scope of this report to assess
whether all or parts of these projects are considered
major civil works and whether the ESF Good Practice
Note is applicable. It is also outside the scope of
this report to assess whether or not they should
have included fewer or more forms of sexual and
gender-based violence as risks and whether or not
the inconsistencies in terminology was intentional.
Regardless, the Good Practice Note recognizes
69 As an example, the Uganda SEP says, “[T]he MoH will collaborate
with the Ministry of Gender and other relevant actors to ensure the
dissemination of information on available services for SGBV, use of
established response hotlines and community outreach” notably to
report cases of VAC and SEA. See: Borrowing Agency, “SEP - Uganda
COVID-19 Project,” 9; Gordillo-Tobar, “SEP - El Salvador COVID-19
Project,” 8.
70 The Bangladesh project only says that GBV issues will be addressed
in the bidding process for contractors with regards to “ESS2 Labor and
Working Conditions” under “Specific Risks and Impacts” and a separate
GRM is required for potential complaints associated with ESS2. See: “Environmental and Social Framework,” 34, par. 21; Mohammed-Roberts,
“ESRS - Bangladesh COVID-19 Project,” 7.
71 Besarabic Bennett, “SEP- Burkina Faso COVID-19 Project,” 13;
Besarabic Bennett, “ESRS - Burkina Faso COVID-19 Project,” 4-5.
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