provide “sufficient time” for these communities to go through their decision-making processes.37 Borrowers should also be aware that there are various strategies that can be used to mitigate barriers to engagements and participating in consultations “by focusing on issues of accessibility, communication, empowerment, and/or confidentiality.”38 Borrowers may need to use separate consultation formats for “women, children, youth, and the elderly, or other groups” depending on the societal context.39 Special accomodations for meaningful consultations in the examined SEP As noted by the Bank’s Template SEP, there are many ways Borrowers can focus on issues of accessibility to mitigate obstacles to stakeholder engagement. Yet, the majority of SEPs did not provide any information about specific accommodations that people might need to effectively engage with the projects and participate in consultations. Table 3 shows that only three SEPs in this analysis list special accommodations to help mitigate obstacles to participating in consultations: Sri Lanka, Guatemala, and the Philippines.40 The SEP for the project in Sri Lanka provides proposed strategies specifically for engaging and disclosing information to each of five vulnerable groups, including designing surveys and “other engagement activities so that women in unpaid care work can participate.”41 Guatemala’s SEP says that there is a “need for interpreters for Indigenous languages, and sign language as necessary, in order to ensure patients and their families understand key messages” of the project.42 Yet, despite the reference to the need for interpreters in the Guatemala SEP, merely including this accommodation would not be sufficient to meet the ESS7 requirements, which call for consultations to involve representative bodies from Indigenous peoples, and to provide sufficient time to allow them to undergo their own collective decision-making processes. The SEP for the Philippines project, on the other hand, indicates specifically it will conduct consultations in a way to meet the requirements of ESS7. It does not list specific accommodations that the project will use, but it states that it will conduct “targeted consultations with indigenous peoples’ 37 See 5e under ESS7 in Annex 1; “Environmental and Social Framework,” 79, par. 23(b). 38 See 3m under ESS10 in Annex 1; “Guidance Note: ESS10,” 4, GN11.1. 39 See 3l under ESS10 in Annex 1; “Guidance Note: ESS10,” 4, GN10.2. 40 The El Salvador SEP does not detail special accomodations for conducting consultations, but as noted in B.1 above, it proposes special forms of information disclosure to publicize consultations. 41 Kak, “SEP - Sri Lanka COVID-19 Project,” 13. 42 Cavagnero, “SEP - Guatemala COVID-19 Project,” 7. BANK INFORMATION CENTER | MAR 2021 representatives and organizations” by identifying appropriate Indigenous Peoples’ organizations and use “engagement approaches that are culturally appropriate that allow for sufficient time for feedback and decision-making processes.”43 Without any updates to the SEP (discussed further in E.2 below), the Borrower has only asserted it intended to meet the ESS7 requirements, but does not indicate the modalities through which it will engage in a “culturally appropriate” manner. In not providing documentation about the culturally appropriate formats they will use for consultations, the other eight projects appear to be out of compliance with Borrowers’ requirements to provide these formats and remove barriers to stakeholders participating in projects, especially those that are “disadvantaged or vulnerable.” If they cannot fully engage in consultations and other forms of engagement, stakeholders cannot provide their input about the project and its risks and benefits. It is also much more difficult for stakeholders to take advantage of project benefits if they do not fully understand them, or if information is presented in a way that is culturally inappropriate. See “Special accomodations for meaningful consultations” in Annex 3 for more information. 2. Clear timelines and personnel for consultations and feedback Relevant ESF requirements and guidance for timelines and personnel for consultations According to the ESF, the Bank is required to monitor stakeholder engagement and consultations by Borrowers.44 If it is appropriate given a project’s particular context, the Bank may also participate in “the consultation activities of the Borrower, including with disadvantaged or vulnerable individuals or groups” to undertake “its due diligence of the project.”45 Borrowers are required to “describe the timing and methods of engagement with stakeholders throughout the life cycle of the project” in the SEP.46 Recognizing that stakeholder engagement is most effective when initiated early in the process of project development, Borrowers must begin consultation with stakeholders early to get their initial views, as well as disclose information about the time and 43 Demombynes, “SEP - Philippines COVID-19 Project,” 6. 44 See 1d under ESP in Annex 1; “Environmental and Social Framework,” 9, par. 50. 45 See 2d under The Directive in Annex 1; “The Directive,” 3. 46 See 3bi under ESS10 in Annex 1; “Environmental and Social Framework,” 98-99, par. 14. 11