MANILA, 7 October 2026 — On the eve of the World Bank Group Annual Meetings in Bangkok, a new analysis reveals the International Financial Corporation (IFC) and its Capitalization Fund made an estimated US$39 million in total return from its investment in a Philippine bank, whose financing of coal-fired power plants left a trail of destruction affecting more than 120,000 people. 

“Our people continue to bear the devastating consequences of IFC’s profiteering,” said Aaron Pedrosa, complainant representative and legal counsel of the Philippine Movement for Climate Justice (PMCJ). “While the bank amassed millions, frontline communities in the Philippines were forced from their lands, suffered respiratory diseases, and faced violence and intimidation for speaking out. Fisherfolk, farmers, and Indigenous Peoples have lost their livelihoods and local ecosystems have been destroyed. The bank to this day has not spent a single dollar for much-needed remedies as impacts continue to be lived realities for affected communities throughout the Philippines. The bank can afford to fund community-level interventions to address livelihood, environmental and health impacts. It has chosen to do nothing.” 

The analysis published today uncovers a calculated commercial strategy. Between 2011 and 2013, the IFC and the IFC Capitalization Fund acquired a significant stake in Rizal Commercial Banking Corporation (RCBC), investing nearly US$148 million. It held shares for 13 years, earning more than US$25 million in dividends from RCBC’s earnings. Despite holding a designated seat on RCBC’s Board of Directors, the IFC stood by as its client bankrolled new coal-fired power plants. The IFC sold shares in 2015 and again in 2025, generating nearly US$14 million in capital gains. This brought the IFC’s total return to an estimated US$39 million. 

PMCJ, IDI and Recourse are calling on the World Bank Board of Directors to surrender the IFC’s multi-million-dollar windfall to those who were harmed by the RCBC investments by contributing to a dedicated fund for the coal-affected communities. 

“This case is the ultimate test of the World Bank’s institutional integrity,” said David Pred, executive director of Inclusive Development International (IDI). “The IFC cannot treat human suffering as a profit-making strategy. While IFC has made a financial killing, thousands of Filipino farmers and fisherfolk are paying the price with their health, livelihoods, and environment. IFC’s Remedial Action Framework exists precisely for these moments – to enable remedy throughout the project cycle and to step in and address harms directly when its clients are unable or unwilling to do so. The World Bank Board must reject the IFC’s excuses and uphold its development mandate by redirecting the returns it earned from the RCBC investment to alleviate the suffering of the impacted communities.” 

Approved by the Board in 2025, the IFC’s Interim Remedial Action Framework (RAF) provides a structured approach to addressing harm arising from IFC investments. Under the framework, IFC can make contributions to remedial action on a case-by-case basis.  

Following an investigation into IFC’s investment in RCBC prompted by a 2017 complaint, the IFC’s independent accountability mechanism, the Compliance Advisor Ombudsman (CAO), found that the IFC had contributed to environmental, social and climate-related harms associated with the RCBC-backed coal plants and concluded the IFC should contribute to remedying those harms.  

Under its Board-approved Management Action Plan, IFC commissioned an independent gap analysis, which confirmed that many of the community-reported harms could be attributed to the power plants and provided 186 recommendations to address the issues. However, following objections from RCBC to the findings, progress has stalled. IFC claims that it has exhausted all options and has refused to publicly disclose the gap analysis reports.  

“Communities across the Philippines are relying on the Board to reject IFC’s total abdication of its responsibilities and restore the integrity of the World Bank on the ground,” said Daniel Willis, Upholding Rights Lead at Recourse. “The independent gap analysis provided 186 clear solutions to fix the harms. Yet, the moment RCBC objected, the IFC folded, hid the findings behind a wall of corporate secrecy, and refused to disclose them to the public. It is a travesty for the IFC to claim its hands are tied while its bank accounts swell with millions from this investment.” 

As the coal plants continue to operate, affected people have demanded that the World Bank Group’s leadership not allow their communities to become sacrifice zones.  

“The IFC made money from funding these coal plants. Now they made money again for selling its shares. That profit was made from our backs,” said Derek Cabe, complainant community member. “That money should go back to us and our communities that the IFC harmed. If the World Bank is serious about being a faster, simpler, bolder, and more efficient bank, there is no better way to prove it than paying for remedies.”  

For more about this case, see here: https://www.inclusivedevelopment.net/cases/philippines-climate-change-and-ifc-lending/  

Read Inclusive Development International’s analysis: “How the International Finance Corporation made an estimated total return of $39 million from its equity investment in Rizal Commercial Banking Corporation” 

The post Philippine Communities Demand World Bank reinvest $39 Million of Toxic Returns in Remedy for Affected People  appeared first on Inclusive Development International.

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:

1. Alignment with international best practice and human rights norms
2. Non-regression from the existing policies of the SF 
3. Improved implementation of the SF
4. 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,

1. AbibiNsroma Foundation 
2. Accountability Counsel 
3. Actions Féministes pour le Développement Durable en Guinée
4. Aid Life Learn Environment 
5. AIDL International Foundation 
6. Alliance Sud 
7. Alternative Law Collective 
8. Arab Watch Coalition 
9. Asia Indigenous Peoples Network on Extractive Industries and Energy 
10. Association for Farmers Rights Defense
11. Association pour l’Amélioration de l’Alimentation de la Mère et de l’Enfant au Sud Kivu/AMEKI-RDC 
12. Association Tunisienne de Droit de Développement
13. ATGL 
14. Bank Climate Advocates 
15. Bank Information Center 
16. BankTrack 
17. Batani Foundation 
18. Both ENDS 
19. Bretton Woods Project 
20. CAN Morocco 
21. CEE Bankwatch Network 
22. Centre de développement de la région de Tensift 
23. Centre for Community Mobilization and Support NGO 
24. Centre for Financial Accountability 
25. Children Advocacy Forum Sierra Leone 
26. Christian Aid
27. Community Climate and Energy Shield Initiative (CCESI) Uganda 
28. Community Empowerment and Social Justice Network 
29. Compassion in World Farming International 
30. Cultural Survival 
31. Debt Justice Norway 
32. Deep Sea Mining Campaign 
33. Derecho Ambiente y Recursos Naturales 
34. Dibeen for Environmental Development 
35. Earthworks 
36. Environment Governance Institute Uganda 
37. European Network on Debt and Development, Eurodad 
38. Fair Finance International 
39. Femimpact 
40. Femmes-Santé-Développement (FESADE)
41. FORED – PNG
42. Friends of the Earth Japan 
43. Friends of the Earth US 
44. Fundación Ambiente y Recursos Naturales (FARN) 
45. Fundación CAUCE: Cultura Ambiental – Causa Ecologista 
46. Fundeps 
47. Germanwatch 
48. Global Surgery Umbrella
49. Green Advocates International 
50. Hermetica International LLC 
51. Inclusive Development International 
52. Industrious Labs 
53. Inisiasi Masyarakat Adat 
54. International Trade Union Confederation  
55. Jamaa Resource Initiatives 
56. Japan Center for a Sustainable Environment and Society (JACSES) 
57. Jewel Environmental Initiative 
58. JUHUDI Community Support Center 
59. Just Ground 
60. Lawyers’ Association for Human Rights of Nepalese Indigenous Peoples (LAHURNIP) 
61. Malaria & NTDs Youth Corps Guinea 
62. Maurisante 
63. MenaFem Movement for Economic Development and Ecological Justice 
64. MiningWatch Canada 
65. Mouvement d’Action des Jeunes de l’Association Centrafricaine pour le Bien-être Familiale 
66. Nigerian Women Agro Allied Farmers Association 
67. OECD Watch 
68. Oil Change International 
69. Open Society Platform The Gambia 
70. Oxfam 
71. Oyu Tolgoi Watch 
72. Pakistan Fisherfolk Forum 
73. Participatory Research & Action Network
74. Peace Point Development Foundation
75. Phenix Center 
76. Philippine Movement for Climate Justice 
77. Power Shift Africa 
78. PowerShift e.V. 
79. Protección Internacional Mesoamérica 
80. Quest For Growth and Development Foundation 
81. Rainforest Action Network 
82. Razom We Stand 
83. Recherche Sans Frontières 
84. Recourse
85. Reporter Brasil 
86. Fédération Intègre pour la Reconstruction et le Développement 
87. Rivers & Rights 
88. Sierra Leone Alliance Against Hunger and Malnutrition 
89. Sinergia Animal 
90. SIRGE Coalition 
91. Social Justice Platform 
92. Southern Initiatives, Myanmar 
93. Stop Financing Factory Farming Coalition 
94. Strategic Response on Environmental Conservation
95. Strategic Youth Network for Development
96. Sukaar Welfare Organization
97. SUN Civil Society Alliance of Liberia
98. Sustentarse (Chile) 
99. SynDev 
100. Tallgrass Institute 
101. Tanzania Institute of the Blind
102. The Common Initiative
103. Transparentem 
104. Trend Asia 
105. Urgewald 
106. Uzbek Forum for Human Rights
107. WaterAid 
108. Wedyan Association For Society Development 
109. Wemos 
110. World Animal Protection 
111. World Economy, Ecology & Development
112. World Food Forum Rwanda
113. Wote Youth Development Projects CBO 
114. Yemeni Observatory for Human Rights
115. Youth in Agroecology and Restoration Network 
116. Zimbabwe Civil Society Organisations Scaling Up Nutrition Alliance  

Read more about Inclusive Development International’s campaign for a stronger sustainability framework at the International Finance Corporation here: https://www.inclusivedevelopment.net/policy-advocacy/a-stronger-sustainability-framework-at-the-international-finance-corporation/

The post Joint Letter Calling on the Board of the World Bank Group to Support Stronger Environmental and Social Safeguards for IFC and MIGA Projects appeared first on Inclusive Development International.

The recent decision by the World Bank Group Board of Directors to invalidate the IFC Compliance Advisor Ombudsman’s (CAO) investigation of IFC’s microfinance investments in Cambodia is unprecedented. As a result of the Board’s actions, CAO Director General Janine Ferretti resigned. Not only does the Board’s decision undermine trust in the World Bank Group’s accountability system, it also undermines the work of all independent accountability mechanisms (IAMs). If institutions’ Boards can disrupt pre-established (and Board-approved) accountability processes on an ad-hoc basis, stakeholders can’t trust or rely upon the legitimacy or predictability of IAMs. And we have seen time and again that these scenarios can easily become a race to the bottom on accountability, as other institutions follow suit. As the network of IAMs, IAMnet must use its collective power to push back on this encroachment on accountability; otherwise, all of your work is at stake.

As civil society organizations who advocate for accountability in international finance and have interacted with IAMnet for many years, we call on IAMNet to:

• Immediately issue a public statement condemning the World Bank Group Board’s decision and discussing the broad implications for development accountability. We refer you to this public statement from 103 civil society organisations and experts on the harms of the decision; and
• Suspend CAO’s IAMNet membership until assurances can be made concerning its independence. Operational independence is a criterion for IAMnet membership. Through the actions of the World Bank Group Board, CAO is not currently operationally independent as evidenced by the directive from the Board that restricts CAO’s ability to process existing and future microfinance complaints according to the CAO policy.

Your action or inaction during this time will speak volumes and will indicate to us whether and how we should continue our engagement with the network. We welcome a conversation to discuss how to protect communities’ access to IAMs during this time.

Sincerely,

Accountability Counsel

African Law Foundation (AFRILAW)

Arab Watch Coalition

Bank Information Center

Buliisa Initiative for Rural Development Organisation (BIRUDO)

CEE Bankwatch Network

Green Advocates International

Global Alliance for Incinerator Alternatives

Asia Pacific Jamaa Resource Initiatives

Inclusive Development International

Recourse

Society for WOmen Rights and Development (SWoRD) Pakistan

Sustentarse

Urgewald

CC: African Development Bank – Independent Recourse Mechanism Asian Infrastructure Investment Bank – Project Affected People’s Mechanism KfW Development Bank – KfW Central Complaints Office Black Sea Trade and Development (BSTD) – Complaints Mechanism Caribbean Development Bank (CDB) – Projects Complaints Mechanism, the Office of Integrity Compliance and Accountability European Bank for Reconstruction and Development (EBRD) – Independent Project Accountability Mechanism (IPAM) European Investment Bank (EIB) – Complaints Mechanism (EIB-CM) FinDev Canada – Independent Accountability Mechanism French Development Agency (AFD) – Environmental and Social Complaints Mechanism German Development Bank (DEG), Netherlands Development Finance Company (FMO), & Proparco – Independent Complaint Mechanism Green Climate Fund (GCF)- Independent Redress Mechanism Inter-American Development Bank Group (IDB) – Independent Consultation and Investigation Mechanism (MICI) International Finance Corporation/Multilateral Investment Guarantee Agency (IFC/MIGA) – Compliance Advisor Ombudsman Internationale Klimaschutzinitiative (IKI) – Office of the independent complaint mechanism (IKI ICM) Japan Bank for International Cooperation (JBIC) – Office of Examiner for Environmental Guidelines Japan International Cooperation Agency (JICA) – Examiner for the Guidelines Nippon Export and Investment Insurance (NEXI) – NEXI Objection Procedures on Environmental Guidelines Nordic Investment Bank (NIB) – Office of the Chief Compliance Officer U.S. International Development Financial Corporation (DFC) – Independent Accountability Mechanism United Nations Development Program (UNDP) – Social and Environmental Compliance Review and Stakeholder Response Mechanism World Bank – Inspection Panel and Dispute Resolution Service

The post Joint Letter to IAMnet Regarding the World Bank Board’s Invalidation of CAO Investigation into IFC Microfinance Investments appeared first on Inclusive Development International.

A CAO investigation found that IFC violated its own Sustainability Framework’s requirements in its investments in six banks providing microfinance in Cambodia, and this noncompliance contributed to predatory lending practices that have led to the loss of land and livelihoods, hunger, increased suicide risks, and threats of retaliation against the very communities that are supposed to benefit from microfinance programs.

The harms caused by the microfinance industry in Cambodia are well documented and were confirmed by CAO. However, in an unprecedented fashion, the World Bank Group Board rejected CAO’s noncompliance findings and recommendations to address the harm from its investments. In direct contradiction to the CAO investigation, and without any evidence, the Board published a statement on June 24th declaring that, ”there has been no policy noncompliance under IFC’s Policy on Environmental and Social Sustainability.” Although required by the Board-approved CAO policy, IFC refused to develop and submit to the Board a management action plan with time-bound commitments to address the noncompliance. Instead, it has promised piecemeal actions in a “Special Management Action Plan” that do not address most of CAO’s recommendations. Furthermore, according to unofficial reports, IFC has suggested that victims of predatory micro-finance lending or other consumers harmed by IFC-financed products will no longer have access to recourse through CAO. This is completely unacceptable.

It is not the role of the Board to determine whether or not IFC Management has acted in compliance with its Sustainability Framework. CAO was established to serve as an independent arbiter and hold the institution accountable to the policy commitments made by IFC’s shareholders. If the Board can reject CAO’s policy on a case-by-case basis, then it means that CAO is no longer a reliable and predictable mechanism and can no longer credibly shield IFC from legal liability.

This decision sets a dangerous precedent for accountability at the World Bank Group. It comes at a time when the Board has already shaken the public’s confidence in its accountability architecture by approving a hasty merger of the institution’s public and private sector accountability mechanisms. At this point, the only conclusion we can reach is that the Board prioritizes its investment portfolio over environmental and social protections.

We call upon the Board to:

1. Meet with us to explain how they reached this decision.
2. Publish the voting record of each member of the Board.
3. Require IFC to accept CAO’s findings and develop an effective Management Action Plan in consultation with the complainants.
4. Disclose how any other current and future cases to CAO alleging environmental and social harms stemming from its microfinance portfolio will be handled fairly and predictably.
5. Explain who will be leading CAO following Janine Ferretti’s departure and before the new mechanism is established, and how this leadership vacuum will not further undermine accountability on other CAO cases.
6. Commit to a transparent and inclusive leadership selection process, which includes civil society participation on the selection committee, to ensure the independence and integrity of the new World Bank Group accountability mechanism. Despite the Board’s assertion that a transparent recruitment process has been underway since June 9th, the job posting, terms of reference, and recruitment process have not been publicly disclosed.
7. Reaffirm its commitment to strong due diligence and supervision to ensure that the costs of economic development do not fall disproportionately on poor or vulnerable people.
8. Reaffirm its commitment to strong accountability and ensure that the institution’s new independent accountability mechanism is equipped to do its work effectively.

Signatories

Organizations

1. AbibiNsroma Foundation – Ghana
2. Accountability Counsel – International
3. ATGL – Tunisia
4. Al-Hayat Center – RASED – Jordan
5. Alternative Law Collective – Pakistan
6. Arab Watch Coalition – United States
7. Asia Indigenous Peoples Network on Extractive Industries and Energy (AIPNEE) – Philippines
8. ASOCIACIÓN AMBIENTE Y SOCIEDAD – Colombia
9. Asociación unión de talleres 11 de septiembre – Bolivia
10. Association for Farmers Rights Defense, AFRD – Georgia
11. Bank Climate Advocates – United States
12. Bank Information Center – United States
13. BankTrack – The Netherlands
14. Both ENDS – The Netherlands
15. Bretton Woods Project – United Kingdom
16. CEE Bankwatch Network – Czech Republic 2
17. Center for Economic and Social Rights (CESR) – Global
18. Centre de développement de la région de Tensift – Morocco
19. Centre for Environmental Justice- Sri Lanka – Sri Lanka
20. Centre for Human Rights and Development – Mongolia
21. Cohesión Comunitaria e Innovación Social – Mexico
22. Colectivo Voces Diversas – El Salvador
23. Community Empowerment and Social Justice Network (CEMSOJ) – Nepal
24. Crude Accountability – United States
25. Deep Sea Mining Campaign – United Kingdom
26. Derecho, ambiente y recursos naturales (DAR) – Peru
27. Dibeen for Environmental Development – Jordan
28. Equitable Cambodia – Cambodia
29. ESPOD (Arab Watch Coalition Association) – Morocco
30. FIAN Germany – Germany
31. Fundación Acue – Chile
32. Fundación Ambiente y Recursos Naturales (FARN) – Argentina
33. Fundación CAUCE: Cultura Ambiental – Causa Ecologista – Argentina
34. Fundación Libera contra la Trata de Personas y la Esclavitud en Todas sus Formas – Chile
35. Fundeps – Argentina
36. Germanwatch – Germany
37. Green Advocates International – Liberia
38. Growthwatch – India
39. HRM “Bir Duino -Kyrgyzstan” – Kyrgyzstan
40. Human Rights Law Centre – Australia
41. Inclusive Development International – United States
42. Indigenous Peoples Alliance Of the archipelagos Chapter Sumbawa (AMAN SUMBAWA) – Indonesia
43. Indigenous Peoples Rights International-IPRI – Philippines/Global
44. Inisiasi Masyarakat Adat (IMA) – Indonesia
45. International Accountability Project – Global
46. International Rivers – United States
47. International Work Group for Indigenous Affairs – Denmark
48. Jamaa Resource Initiatives – Kenya
49. Just Finance International – The Netherlands
50. Just Ground – United States
51. Kapaeeng Foundation – Bangladesh
52. KTNC Watch – Republic of Korea
53. Liberia Artisanal Fishermen Association LAFA – Liberia
54. Manushya Foundation – Thailand
55. Mekong Watch – Japan
56. MenaFem Movement for Economic, Development And Ecological Justice – SWANA/Morocco
57. MiningWatch Canada – Canada 3
58. Nash Vek PF – Kyrgyzstan
59. OEARSE – Democratic Republic of the Congo
60. Oil Workers’ Rights Protection Organization Public Union – Azerbaijan
61. Oxfam International – United States
62. Oyu Tolgoi Watch – Mongolia
63. Pakaid – Pakistan
64. Peace Point Development Foundation -PPDF – Nigeria
65. People Ecology Network – India
66. PFAA – Iraq
67. Phenix Center – Jordan
68. Philippine Movement for Climate Justice – Philippines
69. Psychological Responsiveness NGO – Mongolia
70. Recourse – International
71. RimbaWatch – Malaysia
72. Rivers & Rights – Southeast Asia (Regional)
73. Rivers without Boundaries – International
74. Rivers without Boundaries Coalition – Mongolia
75. Sinergia Animal – Global South
76. Society For Women Rights & Development ( SWoRD) – Pakistan
77. Studies and Economic Media Center – Yemen
78. Surge Africa Organisation – Nigeria
79. Sustentarse – Chile
80. SynDev – Senegal
81. The William Gomes Podcast – United Kingdom
82. Transparentem – United States
83. Trend Asia – Indonesia
84. Uganda Consortium on Corporate Accountability – Uganda
85. Urgewald – Germany
86. WEED – World Economy, Ecology & Development – Germany
87. Wemos – The Netherlands
88. Wedyan Association For Society Development – Yemen
89. Witness Radio – Uganda
90. Yemeni Observatory for Human Rights – Yemen
91. Uzbek Forum for Human Rights – Uzbekistan/Germany

Individuals

92. Dr. Guljakhon Amanova – Uzbekistan
93. Ms. Sophia Cramer – Independent Researcher and Policy Advisor
94. Ms. Fiona Faye, University of Kassel, Afrique-Europe-Interact
95. Prof. Daniel D. Bradlow, University of Pretoria
96. Prof. Arntraud Hartmann, SAIS Europe Johns Hopkins University
97. Prof. David Hunter, Peregrine Environmental Consulting, LLC
98. Prof. Emeritus Shin Imai, Osgoode Hall Law School
99. Prof. Aram Ziai, University of Kassel and Global Partnership Network

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The proposal notes that while a rapid shift to renewable energy use is urgently needed, transition mineral mining, large-scale renewable energy infrastructure and other projects being pursued are enormously land-intensive, and current approaches to land acquisition for such projects routinely lead to forced displacement and other rights violations.  

“Unless the major industries involved—including mining companies, their downstream buyers and the development banks and other financial institutions backing them—adopt a fundamentally different approach to how communities are treated when their land is needed for investment projects, we will replicate the injustices of the extractive, fossil economy we are trying to leave behind,” said David Pred, executive director of Inclusive Development International.   

Proposal for a just alternative to development-forced displacement 

The proposed new approach puts forward a framework for shifting policy and practice away from the prevailing paradigm that accepts forced displacement of communities “in the way of development,” towards a new approach to engaging project-affected people that is rooted in respect for their dignity, knowledge and capabilities to make their own development choices.  Core principles include:  

1. Communities should have access to independent technical and legal support to conduct mapping and baseline studies of their land and resources, assess the impacts of project design options, and shape the development benefits they wish to attain from the project. 

2. Designs that avoid displacement and other significant community impacts to the maximum extent possible should be prioritized—only after fully exploring avoidance options should unavoidable impacts be addressed, with a focus on minimizing their duration and maximizing restoration and return of land.  

3. Rights-based mediation that addresses power imbalances should be used to forge fair and equitable agreements that prevent harm to communities and provide compensation and development benefits that sustainably improve their living standards and well-being.  

4. Involuntary resettlement should only be carried out in the most exceptional circumstances, in strict accordance with international human rights law principles—any invocation by governments of “public interest” to justify expropriation and override community objections must be subject to a rigorous human rights assessment. In the case of Indigenous Peoples, expropriation should not proceed without their Free, Prior and Informed Consent (FPIC).  

5. Community-company agreements should be legally binding and enforceable by communities themselves—with the support of legal counsel—through courts, human rights-compliant arbitration, such as under the Hague Rules on Business and Human Rights Arbitration, or other accessible and effective enforcement mechanisms.   

6. Development finance institutions, commercial lenders, investors and buyers should enable this approach by contributing resources for independent technical and legal support for communities and by offering mediation services for upfront agreement making, and they should use their leverage to ensure that obligations to communities are met throughout the project cycle. 

As the leading private sector standard setter on environmental and social issues, the IFC’s adoption of a just approach to community engagement would have a catalytic effect. More than 150 organizations, including financial institutions that are signatories to the Equator Principles, export credit agencies, and Development Finance Institutions rely on the IFC’s Performance Standards, and many individual corporations commit to their implementation in their operations. In April 2025 the IFC commenced a multi-year update of its Sustainability Framework, including the Performance Standards, offering a critical opportunity for change.  

“This moment requires more than tinkering on the edges of the IFC Sustainability Framework. It calls for a wholesale new approach that starts by recognizing affected communities—not as passive stakeholders as they are currently treated—but as rights-holders with the capability and the power to exercise agency over decisions that may fundamentally alter their lives,” said Natalie Bugalski, senior legal and policy director at Inclusive Development International, and the lead author of the proposal.  

“This is not actually a radical proposition—it just means incorporating concrete measures into the Performance Standards that will give effect to the commitment that the IFC and other institutions already make to realizing broad community support for their projects.” 

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We applaud IFC/MIGA for advancing this framework, which contains promising commitments that, if well implemented, could address a troubling history of IFC/MIGA allowing environmental damage and human rights abuses to go unremedied. This has undermined its sustainable development mandate and has damaged communities’ livelihoods. As communities affected by the projects financed by IFC/MIGA and by other development finance institutions still await remedy from harm, this new policy can finally respond to their calls for accountability and remedy in ways that have not been available to them before.

Most notably the Remedial Action Framework sets forth:

• IFC/MIGA’s recognition that it has a role to play in contributing to remedial action when projects result in environmental and social harm.
• IFC/MIGA’s commitment to fund “enabling activities,” including fact-finding, technical assistance, capacity building, and community development programs. IFC/MIGA commits to developing any such programs in consultation with affected communities. Importantly, IFC/MIGA may consider other options for remedial action, which could include direct funding.
• A commitment to implement and monitor the RAF in consultation with IFC/MIGA’s independent accountability mechanism, the Compliance Advisor Ombudsman, and a commitment to regularly engage with various stakeholders during the interim implementation period.
• A commitment to focus on capacity-building for low-capacity clients, especially in poorer and fragile and conflict-affected states, to strengthen their ability to mitigate harm and deliver remedy.
  

However, the framework still falls short of key demands from project-affected communities. Despite acknowledging that remedy often requires funding, the RAF does not explicitly commit IFC/MIGA to financially contribute, even in cases where the CAO has found IFC/MIGA non-compliant. Further, the RAF does not include a systematic funding mechanism or client-side funding requirement.

Additionally, while the RAF also acknowledges financial intermediary sub-projects it provides no specific guidance on applying remedial principles to these investments, even though over half of IFC’s investments are in financial intermediaries.

Likewise, the RAF does not draw a connection with the IFC/MIGA’s Responsible Exit Approach and Principles. These policies go hand-in-hand, thus, a reference to the Principles in the RAF would solidify this interdependence. Notably, since the RAF only applies to current and future projects that could be found eligible for a CAO complaint, communities that are still awaiting remedy from closed out/concluded projects still have no recourse. The RAF should commit to remedy harm caused by past projects even if they have concluded. Often these projects are concluded because IFC/MIGA exited irresponsibly or because the the client pre-paid / paid off the load early. If the RAF does commit to remedy harm in these cases, it fails to provide holistic access to remedy for all communities.

Yet, the approval of the RAF itself is an important step toward shifting the problematic culture within the IFC/MIGA that has left communities to bear the largest risks from development projects. We applaud the IFC and MIGA Boards’ decision and recognize the IFC/MIGA’s leadership in developing a remedial action framework that other development finance institutions can replicate and build on. This interim framework will be implemented over the next three years, and the implementation of this framework will prove if the IFC/MIGA is truly committed to ensuring that impacts that harm communities and exacerbate poverty are fully remedied. The framework should be implemented transparently, and IFC/MIGA should engage with affected communities and civil society organizations to ensure that it is meeting its mark. The final framework should address any shortcomings identified through implementation. We look forward to working with IFC/MIGA to ensure that this framework is impactful.

Endorsing Organizations:

• Center for International Environmental Law, CIEL
• Jamaa Resource Initiatives, Kenya
• Gender Action
• Arab Watch Coalition
• Urgewald
• Recourse
• Accountability Counsel
• Green Advocates International, Liberia
• Bank Information Center
• International Rivers
• Interamerican Association for Environmental Defense, AIDA
• Inclusive Development International, IDI

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(March 13, 2025) – One year ago today, World Bank Group President Ajay Banga apologized to survivors of child sexual abuse at Bridge International Academies, acknowledging “the trauma they experienced” at the World Bank Group-funded schools and committed to supporting them.  A March 2024 report from the World Bank Group’s internal accountability office, the Compliance Advisor Ombudsman (CAO), found that staff of the bank’s private sector arm, the International Finance Corporation (IFC), knew about sexual abuse at Bridge schools and ignored it for years.  In response to the CAO report, Banga promised a “remediation program” designed “with input from survivors.” At the same time, he announced an “external review” of  allegations that IFC staff and Bridge management (aka NewGlobe) colluded to obstruct and delay CAO’s work.

No remedy or relief for survivors

One year on, survivors of child sexual abuse at Bridge schools have received no remedy or relief. The “remediation program” that Banga promised the individuals who were abused at IFC-funded Bridge schools while IFC staff looked the other way is instead being designed as a public good community wide program to provide services for sexual abuse survivors in the districts where Bridge operated.

To meet President Banga’s year-old commitment to the survivors of child sexual abuse at Bridge schools, the Bank Group must provide immediate relief to meet the needs of those survivors. The four survivors who came forward with complaints to CAO have been clear about the support they need to reestablish their lives. Their needs are modest and the Bank Group should provide a way to address them before spending more money on expensive project design consultants. Beyond the four complainants, the Bank Group should also prioritize outreach to the communities around Bridge schools that would support other survivors to come forward should they so wish.

No accountability for the cover-up

Last Friday, the bank issued a short press statement reporting the results of the external review of IFC’s alleged interference with the CAO investigation into child sexual abuse at Bridge schools. IFC did not publish the investigation report itself. This report was commissioned to rebuild trust and confidence in  IFC and  CAO. A secret report cannot achieve that. It must be made public.

According to the bank’s press release, the review found that: “IFC could have cooperated with the CAO investigation in a more timely, efficient, and rigorous manner [but that], IFC’s approach … did not impact the CAO’s ultimate conclusions.”

It is hard to reconcile this tepid statement with the well documented allegations of interference with CAO’s independence from World Bank Group management and its investigation of the abuse at Bridge schools.

The few details in the press statement do not address the following publicly reported facts which led our groups to call for an investigation in first place:

• Between September and December 2020, IFC and Bridge staff discussed and then executed a plan which was designed to “neutralize” CAO’s lead investigator on the Bridge case. The documented aim of this exercise was to delay publication of the allegations of sex abuse at Bridge schools with a view to raising additional capital for Bridge without “spooking investors.”
  • Did this involve misconduct by IFC staff and/or fraud or attempted fraud against Bridge’s other investors? Was the Bank Group’s internal response to these allegations appropriate? We still don’t know.
    
    

• CAO’s lead investigator on the Bridge case was put on involuntary administrative leave shortly before completion of the report.
  • Was this measure retaliatory? Was the report diluted after he was removed and did his removal facilitate dilution of the CAO report? Did the WBG properly apply its whistleblower protection rules? We still don’t know.
    
    

• IFC entered into a Non-Disclosure Agreement (NDA) with Bridge in June 2020. CAO publicly criticized the NDA saying that it was “reached without CAO’s agreement or participation,” and “included commitments from IFC that CAO would not disclose information that the client asserts to be confidential.” CAO has also said the NDA “created an appearance of seeking to chill CAO’s investigation and raised questions as to how CAO could execute its mandate in light of the confidentiality agreement’s provisions” and that it delayed CAO’s process as well as making it more costly.
  • Why did IFC commit to keep information regarding child sexual abuse secret, and what will be done to prevent this from happening again in the future? We still don’t know.
    
    

• There is the perception that former WBG President Malpass pushed former CAO Vice President Gratacós out of his job when Gratacós would not compromise CAO’s independence. This decision was announced shortly after revelation of Bridge child sexual abuse allegations.
  • Did IFC management unduly influence this decision? We still don’t know.  
    
    

• It has been reported that IFC staff destroyed evidence of sexual abuse at Bridge schools.
  • Could this be confirmed? How is this consistent with Freshfields finding that IFC’s lack of cooperation did not impact CAO’s work? We still don’t know.
    
    

• CAO reports that it engaged “independent legal counsel” to review its investigation of the sexual abuse at Bridge schools.
  • Was this legal advisor independent of IFC management, or were they engaged by IFC management? Was material critical of IFC removed from the CAO report following the review by external counsel? We still don’t know.
    
    

To provide any credible response to these questions, the Bank Group’s Board must first publish the full investigation report. Otherwise, stakeholders will continue to question the World Bank Group’s  commitment to accountability and responsible investment.

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After investigating the Bridge 4 case, the CAO concluded that the IFC contributed to the abuse by failing to conduct adequate due diligence and supervision to ensure that the schools were safe, even after multiple cases of abuse were brought to its attention. On the eve of the investigation report release, President Banga sent out an all-staff email saying that he was “sorry for the trauma these children experienced, committed to supporting the survivors, and determined to ensure we do better going forward.”

IFC’s Management Action Plan (MAP) in response to the investigation commits the Bank to, among other things, fund a remediation program for survivors of child sexual abuse in the counties where Bridge operated. However, roughly six months into the MAP’s implementation, we remain concerned that this process will not result in any meaningful outcomes or remedy for former pupils who experienced sexual abuse while under the care of the IFC’s former client, contrary to the stated commitment of President Banga. 

In August 2024, the CAO decided to merge the Learn Capital 1-4 complaints with the ongoing Bridge 4 process. As such, the four complainants, who we represent are now considered formal complainants in the Bridge 4 case and the harm they suffered should therefore be satisfactorily addressed by the Bridge 4 MAP.

Below is a summary of concerns with the IFC’s implementation of the MAP to date. In light of these concerns, and as the formal representatives of four former pupils of Bridge that suffered sexual abuse, we strongly urge the Board to request that IFC Management revise its Action Plan to prioritize consultation with the maximum number of Bridge survivors as is possible, and ensure that the remediation program is fit for purpose to deliver meaningful remedy.  

IFC failed to ensure sufficient involvement of Bridge survivors in the consultation process:

IFC contracted UNICEF and UNFPA to undertake a stakeholder consultation process to inform the design of the remediation program. They conducted an abbreviated consultation process that took only six weeks, with a validation workshop held on October 1 to mark the conclusion of the consultation. Only towards the conclusion of this process, as UNFPA had already compiled the majority of stakeholder feedback, did IFC/UNFPA request a meeting with the complainants. This meeting was held on November 10.

Prior to the November 10 meeting with the complainants, no effort was made to consult  individuals specifically harmed at Bridge schools. UNFPA engaged local civil society organizations and service providers to mobilize  survivors of sexual violence for the consultation, in counties in which Bridge operated, but there was no specific instruction or guidance provided to these mobilizers to prioritize outreach to Bridge survivors. There was also no effort made, nor time allowed, for grassroots-level awareness raising within these counties that would have increased the likelihood of reaching Bridge survivors. We repeatedly put forward requests to the IFC to determine and find appropriate ways to reach out to other Bridge survivors beyond the four complainants. These requests were repeatedly denied on grounds that any targeted outreach efforts would be deemed unethical. 

Furthermore, as we note in the next section, the consultation materials and meetings themselves failed to adequately explain the reason for the consultation. There was no acknowledgement that the process is being undertaken in response to the Bride 4 case or even, in more general terms, in response to harms that arose in the private school sector, and that therefore feedback specifically from Bridge survivors or survivors of CSA in private schools would be of particular value. As such, IFC and the implementing agencies failed to create a safe space for Bridge survivors who would have wished to self-identify and provide feedback to do so. 

As the formal representatives of the four complainants, our organizations made multiple requests for information, including regarding the consultation timeline and methodology, and summary notes or transcripts, as well as seeking clarity on when and how the survivors we represent could participate. None of this information was provided to us throughout the 6-week consultation process, and IFC denied our request to attend any of the consultation meetings either as participants or observers. We were similarly excluded from the October 1 validation workshop. We understand that the CAO, which has a formal mandate to monitor this process, was also excluded. 

Following the merger of the Learn Capital 1-4 complaints with the Bridge 4 case in August 2024, as the UNICEF/UNFPA consultations were reaching closure, the IFC and UNFPA/UNICEF began to make efforts to consult with the survivors we represent. A consultation meeting was held with the complainants on November 10. While this is a positive development, we fear that this belated action will be a case of ‘too little too late.’ A truly survivor centered and trauma informed approach would have prioritized seeking the input of Bridge survivors–including but not limited to the complainants–from the very outset, as the primary stakeholders. We raised this issue repeatedly with the IFC team and it is concerning that this was not done.

The formation of the Advisory Committee further illustrates our concern: We understand that the IFC has assembled an Advisory Committee to advise on the design and implementation of the remediation program, but the members of that committee have so far not been disclosed to us. We question whether any of the committee members have direct contact with Bridge survivors, or close relationships within the community that this program is intended to benefit.

The planned remediation program is not being designed to deliver remedy to Bridge survivors:

We believe there is a high likelihood that the remediation program will not provide meaningful outcomes for children who experienced sexual abuse while in the care of Bridge schools.  

Firstly, and as already mentioned, UNFPA and UNICEF throughout the consultations did not provide the case context and motivation for the consultation, namely that this is a remediation program in response to an accountability process involving Bridge schools, and that the program is intended to address the remedy needs of specific subset of stakeholders. To any participant without prior knowledge of the Bridge 4 case, it would appear as though the World Bank decided to undertake a GBV-related community development program completely out of the blue. This left participants with insufficient context to make informed comments and recommendations during the consultation meetings.

Instead, the consultation meetings focused on gathering information on how to improve the child sexual abuse prevention and response ecosystem in Kenya at a very broad level, with the aim of mapping out what root causes, challenges and opportunities exist. This high-level information is already well documented in the public domain. While we appreciate any intentions to address sector level challenges, the approach taken here raises concerns around the overall cost, performative nature, and value of this exercise, where the resources expended could have been more meaningfully spent on a tailored intervention responding to the needs of Bridge survivors. Short of tailoring the consultation and response to the Bridge case specifically, the scope of the consultation could have at least been limited to focus on the relevant context: response and prevention of child sexual abuse within private schools.

The complainants we represent have clearly communicated their remedial wishes to the IFC and Board (see Annex 1) and there has been no meaningful discussion with the IFC to date on how the proposed remediation program can meet those demands. In a July 2024 meeting, IFC staff stated that they “hope that Bridge survivors will be encouraged to access the services that would eventually be provided through this program,” but they are not applying themselves to ensure that this will occur.

The IFC staff overseeing the Bridge 4 MAP implementation is conflicted:  

We are deeply concerned by the involvement of conflicted IFC staff members in overseeing the design and implementation of the Bridge 4 MAP. 

One individual previously served as an advisor to a member of the World Bank Board of Directors, and during that time was a staunch opponent of compensation and other forms of remedy for Bridge survivors and actively opposed efforts at the Board to include these measures in the Bridge 4 MAP. The individual, having moved from their Board advisory role to the IFC, now has responsibilities that include overseeing the remediation program design and overall Bridge 4 MAP implementation process. This represents a significant conflict of interest and, as such, this individual should be recused from all work on the Bridge case. 

All conflicts of interest should be explored and addressed, including conflicts introduced by persons who were previously involved in managing or overseeing the Bridge/New Globe investment and who should also be excluded from the current design of the remediation program. 

CAO decision to merge Learn Capital complaints with Bridge 4 case deprived the survivors of a thorough and survivor-centered approach to handling their specific cases:

In August 2024, the CAO decided to merge the Learn Capital 1-4 Complaints with the ongoing Bridge-04 process. As such, the survivors we now represent are formal complainants in the Bridge 4 case. Prior to the merger, the survivors were excluded from any opportunity to influence the scope and proposals within the Bridge 4 MAP while it was being negotiated at the Board level, despite requests to IFC and the Board. 

The decision by CAO to merge the cases was against the wishes of the survivors, who felt that a new investigation, or a deferral of their cases pending the outcome of Bridge 4, would have provided them with a greater opportunity for remedy and justice. 

Given that the survivors were excluded during the Bridge 4 MAP negotiation between IFC and the Board, the decision to merge at this point in the process has therefore forced the survivors into a process that is not designed to prioritize and center their voices. We strongly denounce the decision by CAO to merge the cases, depriving the survivors of a thorough and survivor-centered approach to handling their specific cases.

Recommendations:

• The Board should request that IFC revise the Management Action Plan to make it fit for purpose for delivering remedy for the complainants. Namely:
  • IFC should endeavour to undertake additional consultations specifically intended to gather the views of Bridge survivors. IFC should specifically seek the views of Bridge survivors on their remedial wishes, and design a remedial program to directly respond to their reasonable demands. At a minimum, IFC should establish a special component of its broader program that prioritizes the provision of remedies  for Bridge survivors, based on their specific needs.
• The Board should ensure that the consultation report submitted to them by IFC, UNFPA and UNICEF includes specific feedback from Bridge survivors, regarding their remedy needs and how they believe the remediation program could be designed and implemented to meet those specific needs.
• The Board should ensure that IFC disclose publicly the members of the Advisory Committee and its mandate, and ensure that it is holistically constituted and includes members who have direct contact with Bridge survivors, or close relationships within the community that this program is intended to benefit.
• The Board should ensure that IFC removes all staff from the Bridge MAP team who have a real or perceived conflict of interest due to their previous role and positions taken at the Board, or their past involvement in the management of the Bridge / New Globe investment.

Annex: Bridge 4 Complainant Demands and Direct Quotations

When describing their demands for IFC and the implementation process, the Bridge survivors we represent wanted you to know:

“I am the main character in this story,” “The entire wishlist is my demand and I will not choose one demand over another”, “My only priority now is seeing action from IFC.”

“I got into this process so that I could make a difference,” “I want to see change happening, I will feel so good.”

“I want financial compensation for what I went through,” “My experience of abuse impacted my ability to focus while I was a student at Bridge schools, which prevented me from pursuing the level of education I otherwise may have.”

“The perpetrator should be made to face justice.”

“I want to receive training to pursue a career in counseling so I can help other survivors of sexual abuse.”

“Staff in hospitals and police stations should be responsive,” “Treat me nicely without making me feel insecure and like a victim,” “Survivors should be given a safe space to stay until any investigation is over that is far from home or the perpetrator.”

“I want to be given capital to start a business.” The complainant added that any livelihood support should extend beyond the provision of training and capital,  “I want coaching and support so that I can manage the business until it is established and I can be independent.” The complainants also raised the need for community awareness and spoke again about the need to ensure that the perpetrator faced justice.

These remedial demands had all been mentioned in their wish list below as was submitted to the Board on 18 January 2024. 

Complainants’ Wish List:

• Financial compensation for the harms experienced by survivors.
• Financial support for:
  • School fees and related expenses
  • Counselling services for all survivors and their parents or guardians
  • Skills training and related support to cover basic needs
• A space or center where all survivors can receive counselling, case support, medical screening, and mentorship; and parents of survivors can receive education, counselling and other forms of support.
• IFC should provide funds to support a legal case against the perpetrator in Kenyan courts.
  • All survivors should be provided with the resources they need to ensure their confidentiality and safety throughout the legal process (e.g. safe house). 
  • IFC should serve as an observer to the case.
• Bridge should provide a public acknowledgement of and apology for the harm that it caused to pupils, and outline the actions it will take to remedy that harm. 
• Bridge management should ensure that all pupils have access to counselling services when needed. 
• Bridge management should have a policy that better addresses the risk of SGBV in schools, including by strengthening vetting and recruitment of teachers and stricter repercussions for staff implicated in SGBV.
• All teachers at Bridge schools should receive training on child safeguarding and SGBV. The training should be: Continuous; updated to ensure that legal or policy developments are regularly integrated in the training; Compulsory for all Bridge staff in all schools.
• Bridge should ensure that all parents of pupils receive regular sensitization on child safeguarding and SGBV issues. 
• The World Bank Board should communicate to the Kenyan government about:
  • Strengthening enforcement of regulation of private schools, particularly related to child safeguarding. 
  • Strengthening and improving the handling of SGBV cases at police stations
  • Educating and sensitizing communities on SGBV, including addressing and eradicating stigma against survivors of SGBV.

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In recent months, there has been a worrying escalation in the Cambodian government’s repression of critical voices. This has included attacks on two prominent human rights groups, Center for Alliance of Labor and Human Rights (CENTRAL) and Equitable Cambodia. In both cases, the reprisals are linked to the groups’ legitimate human rights activities, and in particular to their efforts to ensure human and labor rights protections in projects supported by the World Bank Group.

We call on World Bank Group leadership to demand that these attacks be stopped and to use its leverage, consistent with its Position Statement on Retaliation Against Civil Society and Project Stakeholders, to ensure human rights defenders and civil society organizations in the country can continue their work without facing further reprisals. 

Attack on leading labor watchdog 

CENTRAL is one of Cambodia’s leading labor rights organizations. On June 28, 2024, the Ministry of Interior requested that the National Audit Authority of Cambodia (NAA) conduct an audit of CENTRAL and a “national security” audit was launched on July 15, 2024. The audit request came just weeks after CENTRAL published a report assessing the effectiveness of Better Factories Cambodia (BFC), a joint program between the International Labor Organization (ILO) and the International Finance Corporation (IFC) of the World Bank aimed at improving working conditions in the garment sector by assessing the compliance of 660 participating factories with international labor standards. CENTRAL’s report found evidence that BFC was failing to identify freedom of association violations in participating factories and made several recommendations to improve BFC’s program, including by making their compliance reports available to workers and providing a grievance mechanism to allow workers to contest its findings.  

The decision to launch a national security audit was preceded by escalating actions by government-aligned unions, including protests outside CENTRAL’s offices, legal complaints against CENTRAL’s staff, and petitions to the Cambodian government to investigate CENTRAL. The audit, which is clearly a response to CENTRAL’s report on the BFC project, has been roundly condemned by the American Apparel and Footwear Association and the Fair Labor Association (representing the apparel brands that source from Cambodia’s factories), United Nations Special Rapporteurs, and national and international civil society organizations. The ILO and IFC have yet to comment.

Attack on leading development watchdog

Eang Vuthy, Executive Director of the Cambodian land rights NGO Equitable Cambodia (EC), is facing baseless criminal charges due to his organization’s advocacy on behalf of communities affected by harmful development projects. At the end of March 2024, Mr. Eang received a summons informing him that he had been charged with Incitement to Commit a Felony or Disturb Social Security—punishable by up to two years in prison—and ordered to appear before an investigating judge at Phnom Penh Capital Court for questioning on 4 April 2024. 

Since 2012, Equitable Cambodia has played a key role in helping communities seek redress for human rights abuses caused by large-scale development and private investment projects—including several World Bank-backed projects—through strategic advocacy and litigation. As a result, the organization and Mr. Eang has faced years-long attacks and judicial harassment, including a defamation charge against him in August 2016 and a six-month-long suspension of the organization in 2017.

The latest criminal complaint against Mr. Eang, filed by the Ministry of Interior, is the most serious attack so far. Moreover, the charges concern Equitable Cambodia’s legitimate activities and day-to-day work supporting communities to file formal complaints to international accountability mechanisms to seek recourse for harms that they have suffered.  These include a high-profile complaint regarding predatory lending and human rights violations caused by microfinance institutions backed by the IFC. The IFC’s Ombudsman was conducting its investigation mission on the case in March-April 2024, when Mr. Eang received his court summons notifying him that he had been criminally charged. He has strong reason to believe that the charges are a reprisal for this work.

A trial and conviction of Mr. Eang would set a dangerous precedent and would have very serious and far-reaching consequences for civil society in Cambodia.

Cambodia’s closing civil society space

These attacks are part of a broader crackdown on civil society that must be stopped before the last remaining democratic space in the country is closed. 

In the years that followed the Paris Peace Agreements in 1991, which ended over two decades of war and horrific atrocities in Cambodia, a vibrant civil society and free press took hold and helped to advance a new era of democracy and human rights in the Southeast Asian nation. This began to change with the adoption of highly restrictive NGO and telecommunications laws in 2015. This was followed by a string of politically motivated prosecutions of opposition party leaders and elected officials, trade unionists and human rights defenders over the past decade, alongside the shutdown of over thirty independent news organizations. Since Hun Manet became Prime Minister last year, this crackdown on critical voices has escalated to target Cambodia’s leading non-partisan human rights organizations. 

While the Cambodian government has a history of repressing and jailing members of the political opposition, the Ministry of Interior’s attempt to criminalize the otherwise legal day-to-day work of registered human rights NGOs and their leaders represents a new level of repression, that threatens the existence of all remaining independent NGOs in Cambodia that provide critical support to the most vulnerable people in the country.

The World Bank Must Speak Out

There are numerous international institutions that provide development assistance to Cambodia, and which have a responsibility to intervene in defense of Equitable Cambodia and CENTRAL, but perhaps none more than the World Bank Group. That is because the recent attacks are believed to be in retaliation for the organizations’ work addressing World Bank programs.   

In 2018, IFC adopted a Position Statement on Retaliation Against Civil Society and Project Stakeholders, where it states that it does not tolerate any action by a client that amounts to retaliation – including threats, intimidation, harassment, or violence – against those who voice their opinion regarding the activities of IFC or its clients. In this statement, the bank notes that “respect for human rights includes the ability of stakeholders to engage freely with IFC and its clients.”  In 2021 IFC also published a “Good Practice Note for the Private Sector, Addressing the Risks of Retaliation Against Project Stakeholders”, which outlines the steps that IFC’s clients should take to screen for, prevent and address reprisals.

We call upon World Bank President Ajay Banga to make clear to the Cambodian government that the Bank will enforce its policy of zero tolerance for retaliation. This means that, before approving any new investments in Cambodia, the World Bank Group Board should verify that the legal harassment of CENTRAL and Equitable Cambodia has stopped and its staff are able to continue to freely engage in their legitimate human rights activities in support of project-affected communities and workers.  

Signed by:

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