venue for proposed public consultation meetings and how stakeholders will be notified about them.47 They are also required to designate which personnel will implement and monitor consultations and other forms of stakeholder engagement.48 When ESS7 is relevant, Borrowers must “prepare a consultation strategy” for Indigenous Peoples/ Sub-Saharan African Historically Underserved Traditional Local Communities.49 As noted above in C.1, they must establish a process of meaningful consultation that “provide[s] sufficient time for Indigenous Peoples/ Sub-Saharan African Historically Underserved Traditional Local Communities’ decision making processes.”50 The template SEP the Bank created for Borrowers also suggests that when key factors about a project are unknown during project preparation, the SEP needs to provide specific details about ways people can get more information when it is known.51 If locations and dates of meetings are not known, the SEP should provide a “general range” of the number of consultations that will occur and the way they will be conducted. 52 Timelines and personnel for consultations in the examined SEPs Despite the requirement for consultations to begin early in the project process, we recognize that the Bank and borrowing countries may not have had enough information to create specific timelines for consultations given the difficulty of reaching stakeholders and setting up initial consultations in the midst of COVID-19 restrictions. As described in further detail below in section C.3, however, implementation has begun on the majority of projects, most of which have been effective since June 2020 and have now had several months to disclose more detailed information about the time and venues of consultations. Generally, the SEPs in this analysis do not provide any specific timelines for when consultations will take place, beyond stating who and what will be consulted on during the preparation and implementation phases of the project. As indicated in Table 3, only five of the 11 SEPs indicate that project staff were able to conduct some consultations during the preparation 47 See 3cii and 3dii under ESS10 in Annex 1; “Environmental and Social Framework,” 99, par. 19(e); 99-100, par. 22(a) and 22(c). 48 See 3fi under ESS10 in Annex 1; “Environmental and Social Framework,” 100, par. 28. 49 See 5a under ESS7 in Annex 1; “Environmental and Social Framework,” 77, par. 12. 50 See 5c and 5e under ESS7 in Annex 1; “Environmental and Social Framework,” 79, par. 23, 23(b); 51 See 3h under ESS10 in Annex 1; “Template for ESS10,” 8. 52 See 3g under ESS10 in Annex 1; “Guidance Note: ESS10,” 8. BANK INFORMATION CENTER | MAR 2021 of the SEP, but due to COVID-19 restrictions, the project staff carrying out consultations met only with very select groups of stakeholders, including some government officials and health sector experts. They did not meet with project-affected parties, such as civil society and marginalized groups (of these, only the Nepal SEP indicates any specific feedback came from these consultations during preparation).53 Four of the analyzed SEPs, including Guatemala’s, provide very few details on the approaches for consultation, and do not designate the personnel who will carry out their implementation. ESS7 is being applied for five of the projects, but Table 3 shows that the SEPs for two of them, Cambodia’s and Nepal’s, do not document plans for engaging and consulting with Indigenous Peoples/Sub-Saharan African Historical Underserved Traditional Local Communities, thereby not fulfilling the commitment to have consultation strategies for these groups. Without evidence that the Borrowers are fulfilling their commitment to disclose information about consultations and set times for them, there is also no evidence that they are providing Indigenous Peoples/ Sub-Saharan African Historically Underserved Traditional Local Communities enough time to make decisions about how their participation and views on project implementation. The Bank also needs access to the time and venues of consultations to fulfill its obligation to monitor consultations and participate in consultations with regards to marginalized communities. But as of now, the SEPs do not follow the guidance to, at the very least, provide a general idea of how many consultations will take place in a given time. D. GRIEVANCE REDRESS MECHANISM (GRM) 1. Consultations about GRMs with representatives of marginalized groups Relevant ESF requirements and guidance for consulting stakeholders on GRMs The Bank must require Borrowers to provide a grievance mechanism to “receive and facilitate resolution of concerns and grievances of project affected parties.”54 Borrowers are required to set up grievance mechanisms that are “expected to address concerns...in a transparent manner that is culturally appropriate and readily accessible to all project53 Bhattarai, “SEP - Nepal COVID-19 Project,” 5. 54 See 1h under ESP in Annex 1; “Environmental and Social Framework,” 11, par. 60. 12