that the emergency nature of the project preparation led to the SEPs lacking details about these plans for stakeholder engagement and feedback from initial consultations, eight of the 11 original SEPs indicate that, beyond the requirement for Borrowers to disclose updated SEPs if they make significant changes to them, they would disclose revised versions of the documents with more information and detail about the plans for stakeholder engagement within 30 days of the projects’ effectiveness.80 The ESCPs, which describe the timeframes on which Borrowers are required to carry out actions, for every project say that the SEPs will be updated in a set amount of time after their effectiveness — nine say within one month, and two say within two months.81 80 Three of the 11 SEPs — The SEPs for The Gambia, El Salvador, and Cambodia — do not specify that a revised SEP will be prepared, and instead say, per ESS10 requirements, that the SEP will “be periodically revised and updated as necessary.” See: Mills, “SEP - The Gambia COVID-19 Project”; Gordillo-Tobar, “SEP - El Salvador COVID-19 Project”; Hyder, “SEP - Cambodia COVID-19 Project.” 81 Per ESP in Annex 1, the ESCP “will form part of the legal agreement” and the Bank “The Bank will require the Borrower to implement the measures and actions identified in the ESCP diligently, in accordance with the timeframes specified.” See “Environmental and Social Framework,” 4 par. 3(d); 9 par. 46-47. 82 Another SEP was disclosed for the Guatemala project in October, but As of the writing of this report, two of the 11 projects — Liberia and The Gambia — have disclosed an updated SEP (The Gambia was one of the three countries that had not committed to disclosing an updated SEP).82 For seven of the nine projects that Table 7: Projects’ commitments to updating their SEPs Country Month project took effect Commitment to update the SEP per the original SEP Commitment to update the SEP per the ESCP Has an updated SEP been disclosed? Burkina Faso June Within 30 days of effectiveness Within 30 days of effectiveness No Liberia April Within 30 days of effectiveness Within 1 month of effectiveness Yes (August) The Gambia April None: “The SEP will be periodically revised and updated as necessary” Within 2 months of effectiveness Yes (October) Uganda August Within 30 days of effectiveness Within 1 month of effectiveness No Bangladesh April Within 30 days of effectiveness Within 60 days of project implementation starting and as early as possible No Nepal April Within 30 days of effectiveness Within 30 days of effectiveness No Sri Lanka April Within 30 days of effectiveness Within 30 days of effectiveness No* Cambodia April None: “The SEP will be periodically revised and updated as necessary” Within 30 days of effectiveness No Philippines May Within 30 days of effectiveness Within 30 days of effectiveness No El Salvador n/a None: “The SEP will be periodically revised and updated as necessary” Within 30 days of effectiveness No* Guatemala n/a Within 30 days of effectiveness Within 30 days of effectiveness No (a new SEP has been disclosed, but it is the original in Spanish) *Note: These projects disclosed updated SEPs in January 2021, but the rest of this report only reflects information about project documents disclosed before December 20, 2021. BANK INFORMATION CENTER | MAR 2021 18