world to fight the pandemic and respond to the “health, economic, and social shocks that countries are facing.”2 Projects were designed to provide funds to countries to, among other things, improve the availability of medical supplies; strengthen disease surveillance systems; and implement public education and behavior change interventions to promote behaviors like hand-washing and social distancing. Emergency response projects were approved in twenty-five countries in a matter of weeks. As of December 2020, 80 have been approved by the Bank’s Board of Executive Directors to receive funding, yet some have still not moved into implementation. These 80 emergency response projects are part of the $104 billion commitment by the World Bank, which is one of the top funders for COVID-19 emergency response in low-income countries. How this funding is used during the pandemic has a huge, potentially life or death, impact on the millions of people that live in these countries. Typically, World Bank management and the Board of Directors have considered health projects to have a low risk of creating harm to affected parties and therefore require less rigorous up front assessment and scrutiny compared to higher risk projects, such as infrastructure where physical works are constructed. Yet, BIC’s work monitoring COVID-19 emergency response projects and other health projects shows that they risk harming marginalized groups who are more susceptible to COVID-19 and less likely to access project benefits.3 When marginalized groups and other stakeholders are included in project design and continue to be involved and engaged throughout the project life cycle, they can help to identify these risks and give input on plans to mitigate them. In fact, the World Bank’s Environmental and Social Framework (ESF) requires that recipients of Bank financing for development projects (“Borrowers”) identify and mitigate any barriers to “disadvantaged or vulnerable groups’’ accessing these project benefits through stakeholder engagement. The Bank is required to support Borrowers in drafting and disclosing information about how they will conduct stakeholder engagement for Bank-funded projects in Stakeholder Engagement Plans (SEPs), which are the main vehicles for planning and documenting how Borrowers will engage stakeholders under the ESF.4 Bank guidance indicates the importance 2 “World Bank COVID-19 Response”; “How the World Bank Group Is Helping Countries with COVID-19.” 3 Burton, “How Well Is the World Bank Implementing Its Environmental and Social Framework in COVID-19 Health Response Projects?” 4 For projects with large-scale potential risks and impacts, the Bank BANK INFORMATION CENTER | MAR 2021 of conducting stakeholder engagement as early as possible in the development of a project to make sure stakeholders receive credible information about it and can offer their views on project design.5 Borrowers are required to disclose information about the risks and impacts of projects in accessible formats and languages, and conduct consultations with stakeholders from preparation through the end of project implementation.6 Annex 1 provides a full set of requirements of the Bank and Borrowers throughout different sections of the ESF that pertain to stakeholder engagement. In the first wave of COVID-19 health response projects, however, BIC was told in conversations with Bank staff that due to the urgency of approving the emergency projects, Bank staff drafted the majority of initial SEPs. They also said that consultations, especially with marginalized groups, were impossible to conduct before project approval due to COVID-19 restrictions in most countries and because of the rapid response nature of project creation and approval. Still, Borrowers were required to show in their SEPs how they plan to conduct meaningful stakeholder engagement throughout the project life cycles. To assess how the Bank and Borrowers planned to fulfill this commitment, BIC undertook an analysis of a sample of COVID-19 emergency response project SEPs to understand how governments planned to engage with stakeholders, particularly the most marginalized. B. METHODOLOGY BIC undertook an analysis of a sample of COVID-19 emergency response project SEPs to see how governments plan aligned with ESF policy requirements for stakeholder engagement detailed in Annex 1. BIC created a questionnaire to assess COVID-19 emergency response project SEPs based on the general components of the documents and ESF requirements. The full questionnaire used to assess each SEP is provided in Annex 2. This review included the use of key-word searches to identify all of the relevant information across different sections of must support countries in developing stand-alone Stakeholder Engagement Plan (SEP) documents, but depending on the risks associated with the project, the elements of the SEP can be included as part of the Environmental and Social Commitment Plan (ESCP) instead. See “Environmental and Social Framework,” 98, footnote 3. See also “Environmental and Social Framework,” 99, par. 14-17. 5 See 3g under ESS10 in Annex 1; “Guidance Note: ESS10,” 1, par. 2. 6 See 3ci and 3dii under ESS10 in Annex 1; “Environmental and Social Framework,” 99, par. 19 and par. 22(a). 4