Budgets for SEP implementation in the examined SEPs Only three SEPs, The Sri Lanka, Cambodia, and Nepal SEPs, provide specific budgets for the SEP: USD 5 million for Sri Lanka, USD 300,000 for Cambodia and USD 200,000 for Nepal. Eight SEPs in this analysis are not consistent with the guidance to document resources that will be devoted to implementing the SEP or to confirm that the budget is adequate. Five do not provide any information about the resources that will be used to manage SEP implementation or where the funding will come from. Funding for projects is allocated to “project components,” which make up broad forms of related support, and three SEPs in this analysis — those of Liberia, Guatemala, and Burkina Faso — indicate that the SEPs will be funded under a specific project component. These countries’ SEPs, however, do not specify the amount of funding under that component that will be used for SEP implementation. Implementing SEPs, including disclosing of information in appropriate languages and formats as described in B.1, is a requirement the Bank must Table 6: Budgets for SEP Implementation Country SEP Did the SEP mention where money would come from for SEP implementation? Did the SEP provide a specific budget allocation for SEP implementation? Burkina Faso Yes No Liberia Yes No The Gambia No No Uganda No No Bangladesh No No Nepal Yes Yes Sri Lanka Yes Yes Cambodia Yes Yes Philippines No No El Salvador No No Guatemala Yes No Total Yes 6 3 Total No 5 8 BANK INFORMATION CENTER | MAR 2021 hold Borrowers to, and Borrowers are instructed to document that there is a budget to do so. Providing a line item budget explicitly for SEP implementation implies that the Bank and Borrowers have thought through the cost and effort that will be necessary to execute the required plans and activities outlined in the document, and that the Borrower will have enough resources to do so. The lack of any budget or mention of where SEP implementation funding will come from in five of the projects indicates that the Borrowers have not confirmed that they have an adequate budget to carry out the activities described in the SEP, which are important requirements for creating inclusive projects and addressing barriers to project benefits. 2. Commitments to revising SEPs Relevant ESF requirements and guidance for revising SEPs As noted in the Background, the Bank is responsible for assisting Borrowers in carrying out the ESSs, including ESS10.75 The Bank must also “require the Borrower to implement the measures and actions identified” in the Environmental and Social Commitment Plan (ESCP), which forms part of a project’s legal agreement between a Borrower and the Bank.76 Borrowers are required, per ESS10, to disclose an updated SEP if significant changes are made to it.77 In cases when other plans, like a SEP, are required to capture all of the obligations of Borrowers beyond what is included in an ESCP, “the ESCP will set out timeframes for the completion of such plans.”78 Borrowers will “implement diligently” the actions described in the ESCP, including the development of other plans, “in accordance with the timeframe[s] specified.”79 Commitment to revising SEPs in the examined SEPs As described in section C.2 many of the project SEPs do not provide details on disclosing information in appropriate languages and formats nor about the logistics of consultations, and almost none of them conducted consultations with civil society prior to beginning project implementation. Acknowledging 75 See ESS1 in Annex 1; “Environmental and Social Framework,” 3 par. 2. 76 See 2b under ESP in Annex 1; “Environmental and Social Framework,” 4 par. 3(d); 9 par. 46-47. 77 See 3biii under ESS10 in Annex 1; “Environmental and Social Framework,” 99, par. 13. 78 See 4ciii under ESS1 in Annex 1; “Environmental and Social Framework,” 29, par. 8. 79 See 4civ under ESS1 in Annex 1; “Environmental and Social Framework,” 29, par. 10. 17