Dear Executive Director,
Four principles to guide the IFC/MIGA Sustainability Framework review
We are writing to you on behalf of 116 civil society organizations (CSOs) that have been engaging IFC and MIGA, since 2024, on the review of their Sustainability Framework (SF).
As IFC and MIGA prepare to provide you with the first draft of the revised SF, ahead of the public disclosure of the policy and the launch of consultations in the coming months, we feel this is an important time to reaffirm with you several core principles that are essential to ensuring the SF is fit for purpose, up to date, and effectively protects affected communities from harm.
These principles are:
- Alignment with international best practice and human rights norms
- Non-regression from the existing policies of the SF
- Improved implementation of the SF
- Open and meaningful consultation of those most impacted by IFC and MIGA projects
While these cross-cutting principles inform all of our engagement with IFC/MIGA on the SF review, CSOs have also produced many technical recommendations on how to improve specific Performance Standards and the Access to Information Policy, or address important themes during the review. All of the submissions sent by CSOs to IFC/MIGA can be found here.
We hope the following proves useful for your engagement with IFC on the draft policy, and look forward to discussing this further with you in the coming months.
1. Alignment of the IFC/MIGA Sustainability Framework with best available practice and human rights norms
It has been almost 15 years since the SF was last updated. Although the 2012 SF and Performance Standards were an important step forward, and in some cases represented a gold standard in environmental and social sustainability at the time, there have since been many developments in human rights norms and approaches which mean that the IFC/MIGA safeguards are no longer the leading standards they used to be.
This point is echoed in the recent Independent Evaluation Group (IEG) assessment of the 2012 SF, which found that it is “less up to date than some peer frameworks in selected areas” as institutions like the World Bank, Asian Development Bank (ADB) and European Bank for Reconstruction and Development have “introduced additional standards to address areas not explicitly covered in IFC’s framework” such as “financial intermediaries, stakeholder engagement and information disclosure, and selected emerging risks”.
Furthermore, as many investigations by civil society and the Compliance Advisor Ombudsman (CAO) attest to, the current safeguards are not preventing harms to affected communities. As such, there is an urgent need to update and improve the existing SF; to prevent harms, minimise reputational risks for IFC/MIGA, bring IFC/MIGA into alignment with the best available practice (including at peer institutions), and regain IFC/MIGA’s leadership role in the field.
Over the years, consensus has grown around the private sector and companies’ responsibilities to respect human rights. An increasing number of companies are now conducting human rights due diligence in line with corporate responsibilities to respect human rights under international standards like the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. IFC/MIGA’s SF should be fully aligned with the UNGPs and its member states’ human rights, climate change, and environmental review obligations under customary international law. The SF should be further aligned with IFC/MIGA member states’ same obligations under treaties such as (but not limited to) the Aarhus Convention, Kyiv Protocol, Escazú Agreement, United Nations Declaration on the Rights of Indigenous Peoples, the United Nations Framework Convention on Climate Change (UNFCCC) and the Paris Agreement.
By aligning their policy and practice with international norms and obligations, we expect IFC and MIGA to adopt an approach that best ensures their projects do no harm to people, animals or the planet. This requires adopting the highest standards of environmental, social and animal welfare impact assessment, that make use of the best available science and methods to assess and prevent harms arising from all types of projects. Consistent with the UNFCCC and Paris Agreement, the revised SF should include explicit, enforceable requirements to assess and disclose climate-related risks and lifecycle greenhouse gas emissions before approval, and to evaluate alternatives and mitigation measures using best available science and methods. Finally, we hope that IFC/MIGA will make a clear commitment to the presumption of disclosure, in alignment with the World Bank, and to more meaningful consultation with project-affected peoples that ensures Broad Community Support and genuine benefits to affected communities.
We are hopeful that the Board will support our efforts to ensure that the SF is fit for purpose for the current moment, and a genuine gold standard in E&S sustainability.
2. Non-regression from the existing policies of the IFC/MIGA Sustainability Framework
Alongside a commitment to improving the existing SF and bringing it into line with international best practice, we urge the Board to also ensure that the review does not result in any weakening of the existing safeguards.
We find it concerning that, in previous CSO consultations on the SF update, IFC management has made reference to aiming for no “net” regression of the policy. This suggests that some areas of the policy will get weaker. In particular, we are concerned that IFC’s policy on Free, Prior and Informed Consent for Indigenous Peoples may be amended to limit its application.
Neither the desire to harmonise standards with peer institutions, nor the push for IFC and MIGA to rapidly grow their portfolios, can justify any attempt to water down the existing safeguards. This would only undermine the global influence and credibility of the Performance Standards, and would create additional reputational risks (and CAO cases) by permitting further harms to be perpetrated against affected communities.
We strongly urge Board members to adopt, at the very minimum, a policy of non-regression when reviewing the draft SF, and to reject any attempts to introduce de facto policy regression. However, as stated above, a policy of non-regression alone is insufficient to prevent the continuation of social and environmental harms suffered as a result of WBG projects.
3. Improved implementation of the IFC/MIGA Sustainability Framework
Strong policies on paper do not always lead to better practices on the ground. CSO analysis and complaints to the CAO have highlighted many times that the implementation of IFC/MIGA’s SF has been inconsistent, often leading to severe harms to affected communities. Some of those cases are documented here.
IFC and MIGA therefore need to focus on improving the implementation of their sustainability commitments in practice. This is something that has been acknowledged by the Board on numerous occasions through the approval of IFC Management Action Plans (MAPs) designed to address harms arising from poor implementation of the SF. The IEG report on the SF also cites implementation as an issue, and recommends that it can be improvised by “expanding hands-on E&S support to clients in higher risk and complex operations and by improving the transparency of its E&S performance and disclosures”.
The IFC and MIGA can also improve implementation by creating and deepening an internal culture of accountability among staff. This includes better incentivizing strong E&S performance and introducing a system that discourages non-compliance with E&S requirements. Staff performance and promotion metrics should be aligned to their respective impacts in effectively implementing the IFC/MIGA SF. This includes IFC/MIGA staff involved in E&S performance across all types of financial products and services throughout their entire lifecycle, including after project closure.
It is also important for the requirements of the SF to be applied more consistently and comprehensively across the many project types (e.g. trade finance, capital markets transactions, microfinance, guarantees and financial intermediary investments) and financial instruments (debt, equity, quasi-equity, private equity, corporate finance, syndicated loans, trade finance, bonds, etc.) that IFC and MIGA engage in. Requirements should apply throughout the investment lifecycle and should cover the client’s subproject portfolios, with proactive disclosure of the end uses and activities supported. Environmental and social risk assessment should also be extended to include cumulative and indirect impacts, associated facilities, material supply-chain impacts and the wider activities materially enabled by an investment. Together, these measures, and appropriate disclosure, would ensure more effective implementation of the SF’s requirements down the investment chain and throughout project cycles.
IFC and MIGA must also carefully consider how to increase their leverage with clients (particularly financial intermediary clients) throughout the project cycle to ensure strong E&S compliance, and to make better use of their existing leverage. The independent Review Team working on the 2026 Targeted Review of CAO’s policy made several recommendations on how IFC can better use leverage to implement MAPs. CAO has also provided useful recommendations for how IFC could maintain leverage throughout an investment cycle, for example by tying disbursements to E&S outcomes, by building client capacity to implement E&S requirements or by using new investments with existing clients as a point of leverage with which to ensure E&S management systems are being properly implemented.
While some of these issues pertain more to IFC’s internal practice than to the policy of the SF per se, updates to IFC’s Sustainability Policy do provide an opportunity to think about client relationships, leverage and E&S implementation more concretely. We urge you to bear this in mind when reviewing the draft policy.
4. Open and meaningful consultation of those most impacted by IFC and MIGA projects
As CSOs highlighted to IFC/MIGA at the start of the review, it is vital that consultations on the draft SF are conducted in an open, transparent, accessible, and meaningful way, that enables those most impacted by IFC/MIGA projects to contribute to improving the safeguards. This is the best way to increase trust that IFC and MIGA are committed to improving E&S outcomes.
IFC’s engagement with CSOs during the pre-consultation phase has been, for the most part, positive and constructive. However, we currently have concerns on two fronts. Firstly, Indigenous Peoples’ organisations requested on multiple occasions that IFC establish an autonomous Indigenous Peoples Advisory Group (IPAG) to engage on the SF update (as ADB did during its recent Safeguard Policy review and has continued for its current Accountability Mechanism Policy review). However, despite many meetings and considerable work done by Indigenous Peoples’ organisations to begin developing a framework for such a body, IFC did not demonstrate good faith and trust towards the Indigenous Peoples’ organisations, who have therefore withdrawn from the process.
Similarly, CSOs requesting consultation on the implications of the SF review for IFC’s health portfolio, given the numerous reports of harm within it, were also effectively ignored.
CSOs also requested that IFC and MIGA engage project-affected persons and communities during the SF review, which they have now committed to do during the public consultation phase. However, plans on how this will be done are currently unclear, as IFC and MIGA have yet to publish or share any details of the Stakeholder Engagement Plan for public consultations.
The details of this plan are vital. Project-affected communities and Indigenous Peoples Organizations are best placed to inform IFC and MIGA of how environmental and social safeguards are likely to impact Indigenous Peoples and other affected communities, and how best to engage them. But consultation must be meaningful and not just a tick-box exercise.
We expect that consultations will not just be held in country capitals or in IFC offices, but will see IFC staff make efforts to go and meet project-affected communities where they are, in locations accessible to communities and all project-affected persons. We expect consultations to be conducted in local languages, with independent facilitation and translation provided, and consultation documents disclosed well ahead of time. We trust that these expectations are shared by the Board, and welcome your support in scrutinising IFC and MIGA’s Stakeholder Engagement Plan, when disclosed, to ensure that they are reflected in the Plan’s approach.
Thank you for considering these principles for the update of IFC/MIGA’s Sustainability Framework. We look forward to discussing this with you further during the Annual Meetings in Bangkok.
Yours sincerely,
- AbibiNsroma Foundation
- Accountability Counsel
- Actions Féministes pour le Développement Durable en Guinée
- Aid Life Learn Environment
- AIDL International Foundation
- Alliance Sud
- Alternative Law Collective
- Arab Watch Coalition
- Asia Indigenous Peoples Network on Extractive Industries and Energy
- Association for Farmers Rights Defense
- Association pour l’Amélioration de l’Alimentation de la Mère et de l’Enfant au Sud Kivu/AMEKI-RDC
- Association Tunisienne de Droit de Développement
- ATGL
- Bank Climate Advocates
- Bank Information Center
- BankTrack
- Batani Foundation
- Both ENDS
- Bretton Woods Project
- CAN Morocco
- CEE Bankwatch Network
- Centre de développement de la région de Tensift
- Centre for Community Mobilization and Support NGO
- Centre for Financial Accountability
- Children Advocacy Forum Sierra Leone
- Christian Aid
- Community Climate and Energy Shield Initiative (CCESI) Uganda
- Community Empowerment and Social Justice Network
- Compassion in World Farming International
- Cultural Survival
- Debt Justice Norway
- Deep Sea Mining Campaign
- Derecho Ambiente y Recursos Naturales
- Dibeen for Environmental Development
- Earthworks
- Environment Governance Institute Uganda
- European Network on Debt and Development, Eurodad
- Fair Finance International
- Femimpact
- Femmes-Santé-Développement (FESADE)
- FORED – PNG
- Friends of the Earth Japan
- Friends of the Earth US
- Fundación Ambiente y Recursos Naturales (FARN)
- Fundación CAUCE: Cultura Ambiental – Causa Ecologista
- Fundeps
- Germanwatch
- Global Surgery Umbrella
- Green Advocates International
- Hermetica International LLC
- Inclusive Development International
- Industrious Labs
- Inisiasi Masyarakat Adat
- International Trade Union Confederation
- Jamaa Resource Initiatives
- Japan Center for a Sustainable Environment and Society (JACSES)
- Jewel Environmental Initiative
- JUHUDI Community Support Center
- Just Ground
- Lawyers’ Association for Human Rights of Nepalese Indigenous Peoples (LAHURNIP)
- Malaria & NTDs Youth Corps Guinea
- Maurisante
- MenaFem Movement for Economic Development and Ecological Justice
- MiningWatch Canada
- Mouvement d’Action des Jeunes de l’Association Centrafricaine pour le Bien-être Familiale
- Nigerian Women Agro Allied Farmers Association
- OECD Watch
- Oil Change International
- Open Society Platform The Gambia
- Oxfam
- Oyu Tolgoi Watch
- Pakistan Fisherfolk Forum
- Participatory Research & Action Network
- Peace Point Development Foundation
- Phenix Center
- Philippine Movement for Climate Justice
- Power Shift Africa
- PowerShift e.V.
- Protección Internacional Mesoamérica
- Quest For Growth and Development Foundation
- Rainforest Action Network
- Razom We Stand
- Recherche Sans Frontières
- Recourse
- Reporter Brasil
- Fédération Intègre pour la Reconstruction et le Développement
- Rivers & Rights
- Sierra Leone Alliance Against Hunger and Malnutrition
- Sinergia Animal
- SIRGE Coalition
- Social Justice Platform
- Southern Initiatives, Myanmar
- Stop Financing Factory Farming Coalition
- Strategic Response on Environmental Conservation
- Strategic Youth Network for Development
- Sukaar Welfare Organization
- SUN Civil Society Alliance of Liberia
- Sustentarse (Chile)
- SynDev
- Tallgrass Institute
- Tanzania Institute of the Blind
- The Common Initiative
- Transparentem
- Trend Asia
- Urgewald
- Uzbek Forum for Human Rights
- WaterAid
- Wedyan Association For Society Development
- Wemos
- World Animal Protection
- World Economy, Ecology & Development
- World Food Forum Rwanda
- Wote Youth Development Projects CBO
- Yemeni Observatory for Human Rights
- Youth in Agroecology and Restoration Network
- Zimbabwe Civil Society Organisations Scaling Up Nutrition Alliance