The ADB’s Accountability Mechanism has historically been seen as a mechanism of last resort, creating barriers to accessibility and leading to one of the lowest eligibility and compliance investigation rates among other Independent Accountability Mechanisms.

The recommendations aim to reduce roadblocks complainants face on the long road to remedy, including eligibility barriers, undue delays, power imbalances, and lack of adequate consultation during the remediation process. They are based on and include case studies, references to good policy at other Independent Accountability Mechanisms, and empirical evidence on the working of the ADB’s Accountability Mechanism for the past 12 years.

You can read a summary of the recommendations here.

The full recommendations are available here.  

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• The International Finance Corporation (the World Bank Group’s private lending arm) has indirectly financed captive coal development in Indonesia, finds a new report released today by climate and human rights organizations. 
• The report highlights the cases of two coal-powered nickel refineries on Obi Island in Indonesia, which are funded by the IFC’s financial intermediary clients. The IFC has indirectly financed at least one of these projects.
• ‘Captive’ coal units [1] are often constructed to power the processing of metals, such as nickel or steel, deemed critical to decarbonisation efforts.
• While nickel processing plants play a role in electric vehicle supply chains, their use of captive coal is undermining energy transition efforts and causing harm to communities. 
• The report argues that the publicly-funded Multilateral Development Banks (MDBs) are at risk of funding a boom in climate-busting ‘captive’ coal, despite commitments to end coal funding and align with global efforts to phase out fossil fuels. 

A new analysis, published today by Recourse, Trend Asia and Inclusive Development International, demonstrates that publicly-funded Multilateral Development Banks are at risk of funding a wave of ‘captive’ coal expansion in climate-vulnerable countries, despite commitments to shift funds from fossil fuels to renewable energy.

Loopholes in existing policy commitments to end coal funding from the World Bank and the International Finance Corporation (the Bank’s private sector arm) mean that these institutions can still fund ‘captive’ coal units designed to support industrial processes [2]. The report highlights two examples of captive coal projects in Indonesia that have been financed by Hana Bank Indonesia and OCBC NISP, financial intermediary clients of the IFC, and argues that the IFC has indirectly financed at least one of these projects.

Captive coal units, usually constructed to support industrial processes such as metal smelting or cement production, are set to become more common in the coming decade. For example, in Indonesia, while the government has committed (under its Just Energy Transition Partnership Plan) to reduce grid-connected coal capacity by almost half between 2030 and 2045, it is set to more than double its captive coal capacity (from 14.2 GW to 32.7 GW) to power its burgeoning transition minerals industry [3]. As a result, captive coal expansion will lead to an overall increase in Indonesia’s coal capacity up until 2045, undermining any reductions in greenhouse emissions achieved through coal decommissioning. 

Daniel Willis, finance campaigner at Recourse, said: “At present, the World Bank Group is blind to the risks that captive coal poses to people and planet. It would be a great irony if, in the name of financing the production of materials needed for the renewable energy transition, multilateral development banks also financed the rapid expansion of climate-busting captive coal. The World Bank Group must focus on supporting climate projects that do no harm, and that accelerate, rather than hold back, the decarbonization of industry.”

The report is published alongside a case study [4] on the impacts of nickel processing and captive coal development on Obi Island in Indonesia, which include air pollution, health problems, biodiversity loss and exacerbated poverty. As the case study details, the IFC has indirectly financed at least one of these projects via a financial intermediary client. Another financial intermediary, which the IFC has funded to invest in climate-friendly projects, has also funded a separate coal-powered nickel facility on the island. 

Novita Indri, energy campaigner at Trend Asia, said: “An energy transition process that still leaves room for coal use is not appropriate or equitable. More coal use will only bring us to the brink of failing to achieve the Paris Agreement goals and will exacerbate the damage and suffering of the environment and people living around Indonesia.”

The report calls on the World Bank Group to close loopholes in its existing policies to ensure that it does support projects related to captive coal, and that it instead supports renewable energy alternatives that do no harm for powering industries. Campaigners are also calling on all Multilateral Development Banks to improve the transparency of financial intermediary investments, and on investors that have supported coal projects to provide remedial action for affected communities. 

David Pred, Executive Director of Inclusive Development International, said:“Captive coal power is still coal power, whatever it’s used for, and comes with the same human and environmental costs. Neither the plants nor the projects that depend on them can be called green and they shouldn’t be getting backing–directly or indirectly–from the World Bank or any institution that is committed to sustainable development.”

END

Photo: Captive coal power plant behind a school on Obi Island. Credit: Esa Setiawan/Trend Asia.

Notes

1. ‘Captive’ coal units are coal-fired power plants that exclusively serve industrial facilities, rather than providing energy to the grid.
2. For example, the IFC’s Green Equity Approach explicitly states that its definition of coal-related projects “excludes captive coal-fired power plants used for industrial applications”. See Page 9: https://www.ifc.org/content/dam/ifc/doc/2023-delta/ifc-approach-to-greening-equity-investments-in-financial-institutions.pdf
3. Just Energy Transition Partnership. (2023). Comprehensive Investment and Policy Plan 2023, p.84. https://jetp-id.org/storage/official-jetp-cipp-2023-vshare_f_en-1700532655.pdf.
4. The two coal-powered nickel smelters in question are the PT Halmahera Jaya Feronikel ferronickel smelter and the PT Halmahera Persada Lygend HPAL nickel refinery.

The post Policy gaps allow World Bank Group to indirectly finance captive coal appeared first on Inclusive Development International.

A range of new coal power projects, including the 2,000-megawatt expansion of Southeast Asia’s largest and dirtiest coal plant, are getting backing from the Asian Development Bank (ADB), according to a new report from the environmental and human rights groups Inclusive Development International, Recourse, Trend Asia and the NGO Forum on ADB. Inclusive Development International discovered the funding as part of an investigation into development finance support for coal in Asia.  

The ADB describes its $600 million loan to Indonesia’s state-run electricity utility—Perusahaan Listrik Negara, or PLN—as an effort to “promote the use of clean energy,” but as the new report reveals, the 2021 loan is effectively providing support to all of PLN’s 10-year business plan. That plan includes expansion of Indonesia’s notorious Suralaya Power Station through the construction of two massive new plants known as Java 9 & 10, which local communities and environmental advocates staunchly oppose, and more than a dozen other coal projects. 

“ADB’s loan agreement doesn’t just fail to exclude coal. If you look closely, it actually allows PLN to use ADB funding for coal-fired power plants,” said Dustin Roasa, research director at Inclusive Development International and author of the report. “The loan’s eligible expenditures expressly cover anything in PLN’s 10-year plan, which does not shy away from new coal, or other fossil fuel projects.” 

The report notes that the ADB has denied, through a spokesperson, that the loan can be used for coal-fired power plants, but there is no coal exclusion clause in the loan agreement itself. Even if the bank had adequately excluded coal on paper, in practice it would have been unable to enforce such a restriction because the money from the loan is disbursed into PLN’s general bank account, according to company reporting, where it is mixed with the rest of the utility’s funds. This falls short of the ADB’s own green financing standards, which require funds be placed in a separate account, allowing for easy tracing and verification.  

“Publicly funded institutions like the Asian Development Bank must include robust coal exclusions in contracts with clients and financial intermediaries in order to end coal finance for good,” said Daniel Willis, finance campaigner at Recourse. “Without these, general purpose loans, or even funds earmarked for green projects, could end up supporting coal expansion. Given the urgency of the climate emergency, development banks must also add all fossil fuels to their lists of Prohibited Activities for financing.”

The new report is being released days before the ADB’s annual general meeting in Tbilisi, Georgia, next week. At its last annual meeting in May 2023, bank President Masatsugu Asakawa announced $100 billion in climate-friendly financing, including funding for renewable energy projects and the early retirement of coal plants, and reaffirmed the bank’s pledge to stop financing new coal. By backing the Indonesian government’s coal expansion plans, it is not only violating that pledge and, it appears, the no-new-coal commitment in its Energy Policy, it is undermining its investments in clean energy in the country.  

“Any new coal plant built in Indonesia is likely to operate for 35 to 40 years. By backing PLN’s coal development plans, the Asian Development Bank is helping to lock Indonesia—a country that is critical to the fight against global climate change—into a future at least partly dependent on the dirtiest of fossil fuels. The consequences of this decision, which will make it difficult for Indonesia to meet its Paris Agreement emissions targets, are global. But they will be felt most acutely by the people of Banten,” said Novita Indri, energy campaigner at Trend Asia. 

The human cost of the ADB’s support for new coal 

The new report includes original reporting and interviews with residents and environmental defenders in Banten Province, Indonesia, which illustrate the devastating real-life impacts of the ADB’s support for new coal power development there. Residents describe how pollution from an earlier ADB-backed expansion of the Suralaya Power Station has displaced families, reduced fish stocks and agricultural yields, and sickened their children.  

Pollution from the Suralaya complex and other nearby coal plants kills an estimated 2,500 Indonesians per year and causes numerous health problems, including respiratory disease and cancer. Banten Province already has some of the highest rates of acute respiratory infections in the country and it is estimated that the added pollution from the Java 9 & 10 plants will cause between 2,400 and 7,300 premature deaths over their expected 30-year lifespan. 

What the ADB can do instead to support the people of Banten Province 

In addition to ceasing its ongoing support for new coal development, the ADB has the obligation to provide remedy for the impacts of its past coal funding, including its support for earlier development and expansion of the Suralaya Power Station in the 1980s and 1990s. As PLN’s benefactor, the ADB also has considerable leverage over whether and how it moves ahead with elements of its 10-year business plan, including the construction of the Java 9 & 10 plants. While the ADB is not subject to a recent complaint filed against other Java 9 & 10 financiers, it has substantial influence to push for the communities’ demands to be met, including their call for the project to be canceled, phased out early, or at the very least brought into compliance with international standards.

“The facts on the ground are clear, the ADB must seize the opportunity of its upcoming Energy Policy Review to close off loopholes for continued financing of coal and other fossil fuels, including through financial intermediary arrangements. In addition, as asserted by community rights advocates and social movements in Indonesia as well as elsewhere across the region where the ADB has bankrolled the development of coal projects, it is critical that the institution’s management and board—who stand culpable for the harms, losses and damages wrought on affected communities and ecologies—first and foremost prioritise addressing outstanding grievances and demands for reparative justice from those living and working in surrounding areas,” concluded Tanya Roberts-Davis, Just Transitions Advocacy Coordinator at the NGO Forum on ADB.

About Inclusive Development International

Inclusive Development International is a non-profit organization that works to advance social, economic, and environmental justice by supporting communities around the world to defend their human rights and environment in the face of harmful corporate activities. Learn more at: https://www.inclusivedevelopment.net

About NGO Forum on ADB

The NGO Forum on ADB is an international network of over 300 affiliated civil society—most of which are based in the Asia Pacific region—that supports efforts of affected communities and allied groups to expose and oppose the social, environmental and climate harms wrought by projects, plans and policies of the Asian Development Bank (ADB) and Asian Infrastructure Investment Bank (AIIB). The Forum also supports collaboration between member and allied groups across national boundaries to challenge regional programs advanced by these banks, such as the ADB’s Energy Transition Mechanism.

About Recourse

Recourse campaigns to redirect international financial flows away from dirty, harmful investments, towards greener and more inclusive development. Recourse works in partnership with others to support communities in their struggle for their rights to be respected and their voices to be heard, and holds financial institutions to account for harms to people and the environment.

About Trend Asia

Trend Asia is an Indonesian independent civil society organization that, in light of the opportunities and threats posed by global climate change, is working to drive Asia’s energy and development transformation away from fossil fuels and wasteful consumption and production and toward a sustainable, clean and renewable energy, people-powered future. 

The post The Asian Development Bank is backing new coal, despite climate pledges appeared first on Inclusive Development International.

The Good Policy Paper is authored by Accountability Counsel, Bank Information Center, Center for International Environmental Law (CIEL), Centre for Research on Multinational Corporations (SOMO), Community Empowerment and Social Justice Network (CEMSOJ), Gender Action, Green Advocates International (Liberia), Inclusive Development International, International Accountability Project, Jamaa Resource Initiatives, and urgewald.

The authors identified 69 good policy provisions currently on the books at 19 different financial institutions, including multilateral development banks, national development finance institutions, and other financiers. To decide which provisions constitute good practice, the authors analyzed the policies of IAMs that are members of IAMNet, using the UN Guiding Principles on Business and Human Rights effectiveness criteria for grievance mechanisms and their own years of experience working alongside project-affected communities through the IAM complaints process. The good policies highlighted also reflect feedback solicited from IAMNet members in 2019.

Key recommendations include:

• An IAM should have a two-fold mandate: (1) to prevent harm and provide effective remedy to project-affected people and the environment, and (2) to ensure institutional accountability and continuous improvement for the financial institution.
• An IAM should have three functions: (1) Compliance Review, (2) Dispute Resolution, and (3) Advisory.
  • Compliance review investigates a financial institution’s compliance with its own environmental and social policies and international standards. Compliance review should result in recommendations and an action plan to address non-compliance with a financial institution’s policies and redress past harms to  complainants.
  • Dispute resolution brings the complainants together with the financial institution’s client and other stakeholders to generate and agree on solutions and remedies for negative impacts. To be effective, the dispute resolution function must take measures to rectify power imbalances that often exist between the parties.
  • Through the advisory function, the IAM provides pragmatic evidence-based recommendations gleaned from the mechanism’s compliance review and dispute resolution casework to illuminate gaps in the financial institution’s policies and their implementation.
• An IAM’s structure should maximize its impartiality, credibility, legitimacy, and independence from the financial institution’s management.
• An IAM’s scope and admissibility rules should minimize barriers to accessing the mechanism’s complaint process and allow complaints to proceed in a predictable, transparent, and effective manner.
• Financial institutions should transparently disclose information about the IAM’s procedures, operations, and cases.

The Good Policy Paper presents the minimum policy provisions of an effective IAM; the featured provisions represent a floor rather than a ceiling. As the paper explains, “Even if there were an IAM that had all of the best existing provisions, which there is not, it would still not be a model policy.” For that reason, the authors also include suggestions for making the existing policies even stronger. For example, IAMs and financial institutions can improve on existing policies by: (1) developing remedy funds to ensure resources for remedial actions; and (2) developing public policies on how financial institution staff engage with the accountability mechanism process.

The Good Policy Paper is a resource that will be updated regularly as existing IAM policies improve and new IAMs are developed. Better policies will feed back into stronger recommendations, a cycle which, the authors hope, will translate into better outcomes for communities.

Click here to download the Good Policy Paper: Guiding Practice from the Policies of Independent Accountability Mechanisms.

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The Railway Rehabilitation Project has impacted approximately 18,000 people living alongside Cambodia’s 642-kilometers of dilapidated railway tracks. At least 1200 families, encompassing approximately 5160 people, were required to move to project-sponsored resettlement sites, while the rest were made to cut the portion of their land, houses and shops that lay within the 3.5 meter “corridor of impact” and allowed to remain in the residual railway right-of-way for at least five years.

After receiving a complaint from affected families in 2012, the Compliance Review Panel conducted a 17-month investigation, which concluded that many of those who were relocated were impoverished by an ill-conceived resettlement process that failed to provide adequate compensation, infrastructure at resettlement sites, and assistance to restore lost incomes and livelihoods.  In response, the ADB Board approved a series of measures recommended by the Panel to provide redress to the displaced families and bring the project into compliance.

The investigation and resulting remedial action plan did not, however, address the plight of hundreds of families who were considered “partially-affected” and allowed to remain temporarily in the right-of-way. Many of those families have found themselves living in cramped conditions – with less than 30 square meters of living space – and no security that they won’t be forcibly evicted in the future. Other families still remain in the corridor of impact and refuse to move the resettlement site 20-30 kilometers away from their current homes, where they have seen their former neighbors driven into destitution.

Frustrated by the lack of attention to their plight, in August 2015, twenty-three affected people requested a new investigation by the Compliance Review Panel.

After conducting an initial assessment, including a site visit, the panel found that the complaint was not eligible for further investigation because it did not present new evidence that wasn’t already considered by the panel in its previous compliance review report.

However, the panel stated the “complainants grievances are real and persistent” and that “they need to be – and can be – adequately and urgently addressed.” According to the panel, there was still “prima facie evidence of noncompliance with ADB’s operational policies and procedures and prima facie evidence that this noncompliance with ADB policies has led to harm or is likely to lead to future harm.”  The panel called for these grievances to be dealt with under the existing remedial action plan that was adopted by ADB’s board following the previous investigation.

The Compliance Review Panel also stated that families who do not wish to relocate to the resettlement site outside of Phnom Penh have a right to receive an alternative resettlement solution. According to the Panel, if, “even after the improvement of the facilities of the resettlement site, an affected person still does not wish to move to the offered resettlement site because it is too distant and would be disruptive to their livelihood, that person ought to be offered an equitable and commensurate compensation package or alternate site that will place the person in the same position as before the project impacts were felt.”

“Now that the Compliance Review Panel has clearly stated that people have a right to choose resettlement options that will not make them worse off, we hope ADB and the Government will get to work finding a fair solution for these families who have been living under threat of demolition for nearly ten years,” said Eang Vuthy, Executive Director of Equitable Cambodia, whose organization is assisting the complainants.

“The Panel made a smart move by issuing this response to the complaint, which makes it crystal clear what is required of ADB and the Cambodian Government, without the need for another lengthy investigation,” said David Pred Managing Director of Inclusive Development International, who has been monitoring the Railway Project resettlement process since 2010. “If ADB is forking over $800 million in development financing to Cambodia over five years, it can surely demand that the poor families who have to give up their homes and jobs to make way for ADB-sponsored projects are adequately compensated and resettled.”

The Compliance Review Panel’s Report on Eligibility is available at the following link:

http://compliance.adb.org/dir0035p.nsf/alldocs/JABM-A295PQ?OpenDocument

The complaint is available at the following link: https://www.inclusivedevelopment.net/wp-content/uploads/2015/08/Cambodia-Railway-Complaint-2-30-August-2015-.pdf

More information about the Cambodia Railway project is available at:

www.inclusivedevelopment.net/railway

The post ADB Compliance Review Panel calls for urgent action to help families living along the railway appeared first on Inclusive Development International.

The Railway Rehabilitation Project has impacted approximately 18,000 people living alongside Cambodia’s 642-kilometers of dilapidated railway tracks.   At least 1200 families, encompassing approximately 5160 people, were required to move to project-sponsored resettlement sites, while the rest were made to cut the portion of their land, houses and shops that lay within the 3.5 meter “corridor of impact” and allowed to remain in the residual railway right-of-way for at least five years.

After receiving a complaint from affected families in 2012, the Compliance Review Panel conducted a 17-month investigation, which concluded that many of those who were relocated were impoverished by an ill-conceived resettlement process that failed to provide adequate compensation, infrastructure at resettlement sites and assistance to restore lost incomes and livelihoods.

Yet, hundreds of families in Phnom Penh and Poipet who were considered “partially-affected” and allowed to remain temporarily in the right-of-way have found themselves living in cramped conditions – many with less than 30 square meters of living space – and no security that they won’t be forcibly evicted in the future. Other families still remain in the corridor of impact and refuse to move the resettlement site some 20-kilometers away from their current homes, where they have seen their former neighbors driven into destitution.

Frustrated by a lack of attention from the Asian Development Bank (ADB) to their plight, 22 affected people requested a new investigation by the Compliance Review Panel this week.

“We have been waiting since 2006 to be meaningfully consulted on resettlement options that will not make our lives worse off,” said Sim Pov, one of the complainants who traveled to Manila this week to present the complaint to the ADB Board of Directors. “We cannot remain where we are and we will not go somewhere where we will become poorer. We understand that this is our right under international law and the ADB’s policies,” he added.

The original 2006 Resettlement Plan committed to ensuring that relocation sites would be no more than 5 kilometers from affected households’ current residences. It also identified three potential relocation sites for affected people living along the Phnom Penh section of the railway. Yet, in 2010 ADB ignored the concerns raised by affected households and non-governmental organizations monitoring the resettlement process and approved an updated plan that dropped the two closest sites, leaving as the only option the notorious Trapeang Anhchanh site, some 20 kilometers outside the city-center.

“Trapeang Anhchanh has long been a human dumping ground for poor people who have been forcibly evicted to make way for the exclusive development of Phnom Penh,” said David Pred, Managing Director of Inclusive Development International, who has been monitoring the Railway Project resettlement process since 2010. “We warned ADB at the time that moving people to this place, where there are no jobs or opportunities, would be a social disaster. They didn’t listen to us and sadly the disaster unfolded just as we predicted.”

“I don’t want to move to Trapeang Anhchanh because I have seen the difficult situation that my former neighbors who moved there have faced,” said Keang Si Yong, one of the complainants. “Their children cannot go to school. They’ve lost their jobs and can’t do any business.  They’re in huge debt and their lives have become worse and worse.  An agency whose mission is to fight poverty should not force us to accept this fate,” she added.

“It is unfortunate that it will probably take another scathing compliance investigation to get ADB to follow its policies and ensure that these families are resettled properly,” said Eang Vuthy, Executive Director of Equitable Cambodia, whose organization is assisting the complainants. “But the communities have tried for years to have an honest dialogue with ADB and the Government about adequate resettlement and the door has consistently remained closed. Hopefully, this new complaint will help pry the door open at last.” 

The full complaint is available here.

More information about the Cambodia Railway project can be found here.

The post Families Threatened by Cambodia Railway Development Again Seek Justice from the Asian Development Bank’s Accountability Mechanism appeared first on Inclusive Development International.

Approximately 80 percent of land in Samoa is governed under customary systems, which entail collective ownership by entire kinship groups, known as aiga.

The matais (chiefs) state in the complaint: “We object to the ADB’s determination to dispense with our customary laws and systems, which have successfully safeguarded the interests of the aiga for millennia… The risk runs high that benefits will flow not to local communities, but to foreign investors and national elites… Meanwhile, members of our aiga will face dispossession from potentially large-tracts of land, foreseeably resulting in loss of income, threats to food security and impoverishment.”

Under a series of projects called Promoting Economic Use of Customary Land, the ADB has driven land and financial sector reforms in Samoa to make it easier to lease customary land and to use those leases as collateral for loans. The ADB wants to create a system through which a single authority figure can unilaterally lease out customary land, without consulting other members of the aiga. Under the reforms, the lease agreement could then be used by the leaseholder to access credit from a bank. But if the leaseholder is unable to repay the loan, the bank can take control of the lease, which could cover large tracts of customary land for decades.

Loan default rates are very high in Samoa. Another ADB-backed scheme that provided loans to small businesses resulted in more than half of the businesses falling behind on their repayments.

The complaint points out that leasing of land to outsiders for long durations, and then mortgaging those leases, comes perilously close to land alienation, forbidden by customary laws as well as the Constitution of Samoa.

Leuluaialii Tasi Malifa, lawyer and matai of Afega village explained: “While the Constitution allows customary land to be leased, it prohibits the alienation of customary land from its rightful owners – the entire aiga, including through a mortgage. The ADB-backed reforms violate the sprit and the letter of this fundamental Constitutional protection.”

Under the ADB-driven reforms, Samoan law has already been changed to allow mortgages over leases of customary land that have been granted by the Minister of Lands, Surveys and Environment, without any consultation whatsoever with the aiga. The matai warn that as a result, Samoans are in danger of experiencing the same type of corrupt land deals as those recently exposed in Papua New Guinea, where local communities have been duped out of large swaths of their customary land.

Dr. Telei’ai Sapa Saifaleupolu, matai of Samatau and Upolu, said: “Our customary systems of consensus building may be slow and frustrating in the eyes of the financial market, but they safeguard our rights and help ensure the equitable distribution of land and its benefits. It is these systems that have ensured our survival as a people into the 21^st century.”

Fiu Mata’ese Elisara, matai of Sili and Savaii and Executive Director of Ole Siosiomaga Society Incorporated, said: “These reforms are incompatible with the indigenous culture and political institutions of Samoa, and they are inconsistent with the needs and aspirations of the Samoan people. The failure of the ADB to comprehend this has sadly meant a missed opportunity to achieve the laudable goal of promoting economic use of customary land in a culturally, socially and politically appropriate manner, and without meddling with our tenure system.”

Dr. Natalie Bugalski, Legal Director at Inclusive Development International, which helped the matai to prepare the complaint, said: “The reforms in Samoa are typical of the ADB’s approach. The development bank has a habit of viewing land solely as a commodity to be integrated into financial markets. The ADB needs to respect the fact that some societies have a different relationship with their land and value its enduring social function above its financial value.”

“By failing to hold meaningful consultations and properly assess the social implications of the reforms, the ADB has violated its own safeguard policies,” Dr. Bugalski added.

The complaint letter states that given the fundamental and adverse changes being imposed on fa’aSamoa, all further reforms should be halted and a full and meaningful country-wide consultation should be carried out.

Lilomaiava Ken Lameta, matai of Vaimoso and Safotu said: “Consultations should ensure people across the country are aware of the reforms and actions and how they may be affected. People should have an opportunity to provide their opinions, which should be taken into account in decision-making. If the ADB and Samoan government listened carefully, they will hear plenty of good ideas to enhance customary land productivity in a way that truly benefits local communities.”

The full complaint is available at the following link:

https://www.inclusivedevelopment.net/wp-content/uploads/2014/08/Samoa-matais-complaint-to-ADB-AM-FINAL.pdf

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