Annex 5: Analysis of Liberia
SEP
→ Neither the original nor revised SEP includes
information about the use of an independent
specialist
1. Introduction
See section A.1 in the main text for more information
about relevant ESF requirements
The original and revised Stakeholder Engagement
Plans (SEPs) of the Liberia COVID-19 Emergency
Response Project (LCERP) are two of 12 SEPs
analyzed by BIC with a focus on five main areas:
stakeholder
identification
and
marginalized
groups; information disclosure and accessibility;
consultations and feedback mechanisms; grievance
redress mechanisms; and SEP implementation.
From conversations with World Bank staff, BIC was
informed that the original SEP for LCERP was written
by World Bank staff. The updated SEP, however,
was prepared by the “Republic of Liberia Ministry of
Health’’ and was disclosed about three months after
the project took effect.1
Our analysis in the main text of this report of all 11
original SEPs was meant to be a broader analysis of
patterns and common themes across the SEPs. Below
we have done a deeper assessment of the language
in the revised Liberia SEP to see whether the updates
were effective in addressing issues identified as
patterns across the original analyzed SEPs. While the
assessment is not necessarily representative of other
SEPs, many of the emergency response project SEPs
included similar language, and a closer examination
allows for more nuanced analysis of how the revised
SEP improved on the original, and what gaps still
remain.
See “Liberia COVID-19 Emergency Response Project”
in Annex 3 for links to the original and revised SEPs,
as well as information about the project.
2. Data and Analysis
Below are assessments and comparisons of the
original and revised LCERP SEPs based on the
questionnaire provided in Annex 1. In most cases,
the revised SEP expanded on or improved content
found in the original, but in some cases, content
included in the original SEP was omitted from the
revised document without explanation. See the main
text for the relevant requirements and guidance that
correspond to each section.
A. Stakeholder Identification and
Marginalized Groups
1. Execution of stakeholder identification
1 See “Effectiveness date”, Chisaka, “ISR - Liberia COVID-19 Project,” 1;
Srivastava, “Revised SEP - Liberia COVID-19 Project.”
BANK INFORMATION CENTER | MAR 2021
As discussed in the main text, the Bank suggests
that Borrowers hire a third party specialist to
identify stakeholders for a substantial-risk project
like the LCERP. Nevertheless, information about
the stakeholder identification process remained
the same between the original and revised versions
and neither indicate that an independent third
party specialist was used nor that the Bank verified
the identification of “disadvantaged or vulnerable
individuals or groups.”
2. Definitions of the term “vulnerability” and
“disadvantaged or vulnerable individuals or
groups”
→ The definition of “vulnerability” did not change
from old to revised SEP, but the groups listed as
“disadvantaged or vulnerable” did
See section A.2 in the main text for more information
about relevant ESF requirements
The definition of “disadvantaged or vulnerable” in
the “Addressing Risks and Impacts on Disadvantaged
or Vulnerable Individuals or Groups” provides a
comprehensive list of characteristics that can lead
groups or individuals to be negatively impacted
by Bank-financed projects or limit their access to
project benefits.2 The Bank must use this definition
to verify that SEPs have identified groups that may
be “disadvantaged or vulnerable” in the context of
the project.3
Neither the revised nor the original LCERP
SEP, however, includes the same definition of
“disadvantaged or vulnerable.” Specifically, none
of the definitions in either document include sexual
orientation, gender identity, or indigenous status
as identities or characteristics that may cause
vulnerability, despite the fact that the Directive lists
them.4 Between the two SEPs, the characteristics
listed as those that can lead to “vulnerability” are
2 The characteristics included in the definition of “disadvantaged or
vulnerable” in The Directive are: age; gender; ethnicity; religion physical,
mental or other disability; social, civic or health status; sexual orientation; gender identity; economic disadvantages; indigenous status;
dependence on unique natural resources. See 2 under The Directive in
Annex 1: “The Directive,” 1.
3 See 2b under The Directive in Annex 1; “The Directive,” 3.
4 See Chisaka, “SEP - Liberia COVID-19 Project,” 6-8; Srivastava, “Revised SEP - Liberia COVID-19 Project,” 25-27.
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