Executive Summary
The World Bank’s support for COVID-19 emergency
response projects has impacted millions of people
in low-income countries who are experiencing
the health and economic shocks of the COVID-19
pandemic. While these projects aim to deploy
important health benefits and infrastructure, they
risk harming marginalized groups who are more
susceptible to COVID-19 and less likely to access
project benefits.1 Early and thorough stakeholder
engagement with marginalized groups and
other stakeholders, however, can help to identify
potential risks of project implementation and allow
stakeholders to provide input on plans to mitigate
them.
BIC examined project documents from a sample of
11 of the 80 COVID-19 emergency response projects
approved as of December 15, 2020, primarily focusing
on the components of the Stakeholder Engagement
Plan (SEP) and other stakeholder engagement
requirements of the Bank and Borrowers’ in the
World Bank’s Environmental and Social Framework
(ESF). While the 11 sets of project documents we
analyzed are not representative of documents the
Bank has prepared beyond COVID-19 emergency
response projects and are only a small sample of
all of the COVID-19 emergency response projects,
this analysis offers insight into requirements that
the Bank and Borrowers may be at risk of failing to
meet, and recommendations for how these actors
can avoid such failure, both in emergency project
situations and beyond. The main findings and
recommendations include:
• The
sample SEPs provided inconsistent
definitions of “vulnerability” and “disadvantaged
or vulnerable individuals or groups” and none
reference all of the groups that meet the criteria
of the Bank’s definition of “vulnerable” per
the ESF. Projects should include a clear and
consistent definition of “vulnerability” in project
documents that at a minimum matches and
refers to the definition in the ESF.
• The majority of SEPs in the sample have not
been disclosed in the official language of the
projects’ countries, and do not list specific
accessibility needs for other information
disclosure. Borrowers should do so, and the
Bank should also disclose this information on
its website.
1 Burton, “How Well Is the World Bank Implementing Its Environmental and Social Framework in COVID-19 Health Response Projects?”
BANK INFORMATION CENTER | MAR 2021
• While about half of the SEPs indicate that there
are plans to perform separate consultations
with Indigenous Peoples, fewer than half list
special accommodations that will be made
for Indiegnous People or other marginalized
groups during consultations.
• None of the SEPs indicate that marginalized
groups will be consulted about the design and
implementation of the projects’ Grievance
Redress Mechanisms (GRMs) and only two state
that they will include women on the committees
that handle grievances. Fewer than half indicate
that the GRMs will take “into account the needs”
of Indigenous Peoples. Borrowers should seek
input on the GRM design from marginalized
communities before project implementation
and prioritize representation in GRM function.
• While a majority of the sample project SEPs
indicate that the project GRMs will be equipped
to handle complaints related to genderbased violence (GBV), they do not consistently
indicate that they will be equipped to handle
complaints related to sexual exploitation and
abuse and sexual harassment (SEA/SH), and
project documents address these risks with
inconsistent terminologys. GRMs should be
equipped to handle GBV, and specifically SEA/
SH, complaints. GRMs, especially those that are
intended to handle SEA/SH grievances, should
be set up in a child-friendly manner.
• Fewer than half of the SEPs in the sample provide
a specific budget allocation for implementing
stakeholder engagement activities.
• Despite the fact that every project committed to
updating their SEPs within at least two months
of taking effect, only two of the 11 projects
in the sample disclosed a revised SEP in that
timeframe. When it is not possible to develop
a detailed plan for stakeholder engagement in
advance of project approval, Borrowers should
always commit to revising the project SEPs within
a specific time frame after project approval. The
commitment should be made explicitly and
consistently across project documents.
1. Introduction
A. BACKGROUND AND MOTIVATION
In March 2020, the World Bank approved the creation
of a COVID-19 Fast Track Facility that would quickly
get money to low income countries around the
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