have not disclosed a revised SEP, Implementation Status & Results Reports (ISRs) show evidence that they have been effective since at least June.83 These seven projects have not delivered on their commitment to revise their projects’ SEPs within one or two months of effectiveness. A list of the month projects took effect; the commitment to update the SEP per the original SEP; the commitment to update the SEP per the ESCP, and whether an updated SEP has been disclosed for the projects is included in Table 7. Regardless of any commitment made in the SEPs themselves to update within a specific time frame, at least 55 of the approved COVID-19 emergency response projects had been in effect for more than 30 days at the time of writing, which should be enough time for projects to undergo “significant changes’’ that the ESF requires to trigger an update.84 Borrowers should have more detail about information disclosure and logistics of consultations, yet only only 13 of these 55 projects have disclosed revised SEPs.85 They should have also had the opportunity to conduct more consultations for feedback on project design and stakeholder engagement. The lack of updated SEPs for these projects either means Borrowers have not changed the information in the SEPs and they are not adequately engaging stakeholders according to the requirements of ESS10, or they have changed the information but have not met their requirement to disclose updated SEPs if significant changes are made to them. In either case, the Bank has not taken the steps to support Borrowers in effectively carrying out ESS10. it appears to be the original SEP translated into Spanish. 83 Project effectiveness dates were determined by looking at the “effectiveness date” listed in on the first page of the most recent (as of December 2020) “Implementation Status and Results Report” (ISR) for the projects. For the projects analyzed in this report, see ISRs for each listed in Annex 3. As an example of a project that is effective, see: “Liberia COVID-19 ISR,” 1. ISRs for the two projects that have not disclosed updated SEPs, Guatemala’s and El Salvador’s, do not include dates next to “effectiveness date.” See Cavagnero, “ISR - Guatemala COVID-19 Project”; Gordillo-Tobar, “Disclosable Version of the ISR - El Salvador COVID-19 Emergency Response Project - P173872 - Sequence No : 01.” 84 As of December 27, 2020, BIC searched project documents to determine if updated SEPs had been disclosed for the 80 COVID-19 emergency response projects approved at that time, and if the approved projects had taken effect. Only 13 Borrowers of the 80 had disclosed updated SEPs. Of the 68 projects that have not disclosed updated SEPs, Implementation Status & Results Reports (ISRs) show evidence that at least 55 projects took effect before November. 85 The countries whose projects have disclosed updated SEPs are: Liberia, Malawi, Georgia, Djibouti, The Gambia, Eswatini, Mali, Nicaragua, Sao Tome and Principe, Tunisia, Uganda, and Yemen. BANK INFORMATION CENTER | MAR 2021 3. Recommendations The urgent and expedited manner in which project documents, including SEPs, were prepared for COVID-19 Emergency Response projects in the Spring of 2020 may have been necessary due to the emergency situation. But at a time when many countries were in lockdown and project staff were unable to perform in-person consultations, stakeholder engagement in some form should have been seen as more important than ever to help stakeholders learn about the projects and the potential benefits they offered. Nevertheless, many of the SEPs in the sample we analyzed lack sufficient information and detail for comprehensive SEP implementation, which should include: disclosing project information, including the logistics of consultations, in easy to understand and culturally appropriate ways; conducting consultations early and often; providing culturally appropriate Grievance Redress Mechanisms; regularly updating SEPs as necessary. They have also not been updated as the project documents committed to and as the ESF requires. 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. Still, we feel that the data and analysis above is instructive in considering best practices for SEPs. BIC makes the following recommendations for how the Bank and Borrowers can approach stakeholder engagement in line with the ESF and good practice. Borrowers should: Stakeholder Identification and Marginalized Groups • In emergency projects and projects classified as high or substantial risk, use an independent specialist with experience in the project context to conduct stakeholder identification. Hiring an independent specialist with specific expertise in identifying sensitivities around marginalized groups in that context will help to more comprehensively identify stakeholder groups and include “disadvantaged or vulnerable individuals or groups.” • Use a clear and consistent definition of “vulnerability” in project documents that at a minimum matches and refers to the definition in the Directive. Information Disclosure and Accessibility • In advance of stakeholder engagement 19