emergency response projects. Still, in conjunction with an analysis of the ESF, even the findings from these 11 projects and their documents show that the Bank and these 11 Borrowers did not and have not fulfilled their commitments to laying the groundwork for effective stakeholder engagement, leaving marginalized groups at greater risk of exclusion. 2. Analysis A. STAKEHOLDER IDENTIFICATION AND MARGINALIZED GROUPS 1. Execution of stakeholder identification Relevant ESF requirements for stakeholder identification The Bank is required, according to the ESP, to use all relevant information about projects and their potential risks and impacts to classify them into one of four risk classifications: High, Substantial, Moderate, or Low.7 It is also required by the Directive to review Borrowers’ SEPs “to verify that the SEP identifies the disadvantaged or vulnerable individuals or groups” of the project.8 The Bank can require Borrowers to use independent specialists to assist with identifying these “disadvantaged or vulnerable individuals or groups” and assessing the risks and impacts on them.9 Borrowers are required to carry out environmental and social assessments and to include stakeholder engagement as an integral part of them.10 For High or Substantial risk projects, Borrowers must use independent specialists to conduct the assessments.”11 They may be required to have independent third party specialists assist with identifying stakeholders “depending on the potential significance of environmental and social risks and impacts.”12 Stakeholder identification in the examined SEPs Of the 11 SEPs analyzed for this report, all but one received a “substantial” social risk rating in their Environmental and Social Review Summary (ESRS) documents (See Table 1: The Gambia’s received a 7 See 1a under ESP in Annex 1; “Environmental and Social Framework,” 6, par. 23 8 See 2b under The Directive in Annex 1; “The Directive,” 3. 9 See 2c under The Directive in Annex 1; “The Directive,” 3. 10 See 4ai under ESS1 in Annex 1; “Environmental and Social Framework,” 18, par. 24. 11 See 4aii under ESS1 in Annex 1; “Environmental and Social Framework,” 19, par. 25 12 See 3aii under ESS10 in Annex 1; “Environmental and Social Framework,” 98, par. 10. BANK INFORMATION CENTER | MAR 2021 “moderate” rating). Yet none of the SEPs indicate that an independent third party specialist was used to identify stakeholders, nor indicate that the Bank verified that Borrowers identified the “disadvantaged or vulnerable individuals or groups.” Though it is not required, the SEPs do not provide explanations for why groups were listed as “affected parties,” “other interested parties,” or “disadvantaged or vulnerable groups,” which makes it difficult to ascertain whether the Bank verified that all “disadvantaged or vulnerable groups” were listed in the SEP. Differences between the “disadvantaged or vulnerable groups” listed in the original and revised Liberia SEPs raises the question of whether any verification was done, and why some groups were not included in the original, and why others were removed from the original.13 BIC was told in conversations with Bank staff that the Bank itself drafted the majority of SEPs, and all but one (Sri Lanka) of the 11 SEP examined in fact appear to have been written by Bank staff. Still, it appears that these SEPs could have benefitted from having an independent specialist conduct social assessments and stakeholder identification — specifically identification of individuals or groups defined as “disadvantaged or vulnerable” according to the Directive — in projects with substantial social risks, or to verify all “disadvantaged or vulnerable individuals or groups” are listed. 2. Definitions of the terms “vulnerability” and “disadvantaged or vulnerable groups” Relevant ESF requirements for defining “vulnerability” and “disadvantaged or vulnerable groups” As described in the ESP, the Bank is required to follow the directions established by the “Bank Directive Addressing Risks and Impacts on Disadvantaged or Vulnerable Individuals or Groups.”14 These directions pertain to “the identification of, and mitigation of risks and impacts on, individuals or groups who, because of their particular circumstances, may be disadvantaged or vulnerable.”15 The definition of “disadvantaged or vulnerable” in the Directive provides a list of characteristics that can lead groups or individuals to be negatively impacted by Bankfinanced projects or limit their access to project benefits.16 13 Chisaka, “SEP - Liberia COVID-19 Project”; Srivastava, “Revised SEP - Liberia COVID-19 Project. 14 “Environmental and Social Framework,” x, par. 7. 15 See The Directive in Annex 1; “The Directive,” 1. 16 Ibid. 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 6