Table 3: Plans for and Execution of Meaningful Consultations Country SEP Is ESS7 being applied, according to the ESCP? Does SEP document plans for separate consultations with Indigenous Peoples? Does SEP list that special accommodations will be used for consultations?* Does SEP describe consultations with government officials before project effectiveness? Burkina Faso No No No Yes Liberia No No No No The Gambia No No No No Uganda Yes Yes No No Bangladesh Yes Yes No No Nepal Yes No No Yes Sri Lanka No No Yes Yes Cambodia Yes No No Yes Philippines Yes Yes Yes No El Salvador Yes Yes No No Guatemala Yes Yes Yes Yes Total Yes 7 5 3 5 Total No 4 6 8 6 *Many of the SEPs in the sample explain that “engagement with the vulnerable groups and individuals often requires the application of specific measures and assistance aimed at facilitation of their participation..” A “Yes” in this column, however, entails that the SEP gives at least one example of a “specific measure” that would serve as a way to accommodate stakeholders during consultations, including: interpreters; use of sign language; providing materials in accessible formats such as braille or large print. BIC has made a distinction between accommodations that only serve to make disclosed information understandable and accommodations that serve to facilitate stakeholder participation in consultations. See “Special accomodations for meaningful consultations” and “Clear timelines and personnel for consultations” in Annex 4 for additional data analysis. affected parties.”55 Guidance for Borrowers on how to implement ESS7 also indicates that Borrowers should design grievance mechanisms in consultation with project-affected Indigenous Peoples/SubSaharan African Historical Underserved Traditional Local Communities and that they should “take into account the cultural attributes” and the “traditional mechanisms for raising and resolving issues” in these communities.56 Consulting stakeholders on GRMs in the examined SEPs All projects’ SEPs describe their planned grievance redress mechanisms (GRM). Yet all of the GRMs could be improved to address concerns of marginalized communities and other project-affected groups in culturally appropriate ways by soliciting the feedback 55 See 3ei and 3eii under ESS10 in Annex 1; “Environmental and Social Framework,” 99, par. 27-27(a). 56 See 5f under ESS7 in Annex 1; “Guidance Note: ESS7,” 14, GN34.2. BANK INFORMATION CENTER | MAR 2021 of Indigenous Peoples and other marginalized groups. ESS7 is being applied for at least five of the projects that were analyzed.57 Table 4 shows that three of those five projects’ SEPs, those of the Philippines, Cambodia, and Guatemala, indicate that the projects’ GRMs will take “into account the needs” of Indigenous Peoples.58 The two other projects for which ESS7 is being applied do not mention making sure their GRMs take into account how to handle the grievances of Indigenous Peoples in a culturally appropriate manner. None of the SEPs indicate that the projects 57 Project ESRSs do not use the word “applied” and instead state whether ESS7 is “relevant” or not to a project. Determining whether ESS7 should be applied to projects beyond the five that explicitly state it is “relevant” is outside the scope of this report. 58 As an example, see: Demombynes, “SEP - Philippines COVID-19 Project,” 10. 13