IFC's Guidance Note 1: Social and Environmental Assessment and Management Systems
IFC's Guidance Note 1: Social and Environmental Assessment and Management Systems
IFC's Guidance Note 1: Social and Environmental Assessment and Management Systems
This Guidance Note 1 corresponds to Performance Standard 1. Please also refer to the
Performance Standards 2-8 as well as the corresponding Guidance Notes for additional
information. Bibliographical information on all reference materials appearing in the text of this
Guidance Note can be found in the References Section at the end.
Introduction
Objectives
To identify and assess social and environment impacts, both adverse and
beneficial, in the project’s area of influence
To avoid, or where avoidance is not possible, minimize, mitigate, or
compensate for adverse impacts on workers, affected communities, and the
environment
To ensure that affected communities are appropriately engaged on issues that
could potentially affect them
To promote improved social and environment performance of companies
through the effective use of management systems
G1. A Social and Environmental Management System is part of the client’s overall
management system for the project. It includes the organizational structure, responsibilities,
policies, procedures and practices, and resources, and is essential for successfully
implementing the project-specific management program developed through the social and
environmental assessment of a project. Performance Standard 1 underscores the importance
of managing a project’s social and environmental (including labor, health, safety, and security)
performance throughout the life of the project. A good management system enables continuous
improvement of the project’s social and environmental performance, and can lead to improved
economic, financial, social and environmental project outcomes.
G2. Before IFC proceeds with an investment, IFC reviews the client’s social and
environmental management system. For details on IFC’s process of social and environmental
review, see the Environmental and Social Review Procedure, and for further information on
examples and benefits of improving sustainability performance, see IFC’s sustainability
resources (listed in the References section below).
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Scope of Application
2. This Performance Standard applies to projects with social or environmental risks and
impacts that should be managed, in the early stages of project development, and on an
ongoing basis.
Requirements
G3. The level of detail and complexity of the social and environment management system
and the resources devoted to it will depend on the level of impacts and risks identified in the
social and environmental assessment and the size and nature of the client’s organization. A
satisfactory Management System appropriate to the nature and scale of the project and
commensurate with the level of social and environmental risks and impacts is a condition of
IFC’s investment. If the client does not have a satisfactory Management System at the time of
IFC’s appraisal of the project, one should be developed and implemented over a reasonable
period of time agreed with IFC, and be in effect in time to manage project activities financed by
IFC.
Identification and review of the social and environmental impacts and risks of the
operations
Definition of a set of policies and objectives for social and environmental
performance
Establishment of a management program to achieve these objectives
Monitoring performance against these policies and objectives
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G6. The effort needed to establish a Management System depends on the client’s existing
management practices. Production- and quality-based management systems operating within
the client’s organization can be used as a foundation on which to build the elements of a system
consistent with Performance Standard 1 in the absence of an existing environmental, health and
safety, human resource or social management system. Where a client has an existing
environmental, health and safety, human resource and/or social management system, its
elements may meet or can be appropriately modified or expanded to meet the requirements of
Performance Standard 1. Where a client has developed and implemented a formal
environmental, labor, health and safety, and/or social management system consistent with an
internationally accepted standard, the explicit incorporation of the applicable Performance
Standards in the policy and objectives elements of such system(s) (in addition to the relevant
laws and regulations applicable to their activities, and other corporate priorities and objectives)
and implementation of an appropriate management program may be sufficient to meet the
requirements of Performance Standard 1. Formal management systems certified under
international standards are not required by Performance Standard 1. While certified systems
are likely to meet IFC’s requirements, they do not eliminate the need for IFC’s due diligence of
the elements of the system required by Performance Standard 1.
G7. Even though many formal management systems do not explicitly address it, community
engagement is an important process element in managing social and environmental impacts
and risks, and is specifically included in paragraphs 19 through 23 of Performance Standard 1.
Community engagement normally involves the disclosure of information, consultation with
affected communities (see guidance under paragraph G15 on Stakeholder Identification), and
the establishment of a grievance mechanism. Community engagement should occur as an
integral part of the Assessment and, in the case of projects that have significant impacts on
communities, will normally continue on an ongoing basis during the life of a project. Community
engagement is the responsibility of the client. IFC undertakes its own disclosure of information
in accordance with IFC’s Policy on Disclosure of Information.
5. Risks and impacts will be analyzed in the context of the project’s area of influence. This
area of influence encompasses, as appropriate: (i) the primary project site(s) and related
facilities that the client (including its contractors) develops or controls, such as power
transmission corridors, pipelines, canals, tunnels, relocation and access roads, borrow and
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disposal areas, construction camps; (ii) associated facilities that are not funded as part of
the project (funding may be provided separately by the client or by third parties including
the government), and whose viability and existence depend exclusively on the project and
whose goods or services are essential for the successful operation of the project; (iii) areas
potentially impacted by cumulative impacts from further planned development of the
project, any existing project or condition, and other project-related developments that are
realistically defined at the time the Social and Environmental Assessment is undertaken;
and (iv) areas potentially affected by impacts from unplanned but predictable developments
caused by the project that may occur later or at a different location. The area of influence
does not include potential impacts that would occur without the project or independently of
the project.
6. Risks and impacts will also be analyzed for the key stages of the project cycle,
including pre-construction, construction, operations, and decommissioning or closure.
Where relevant, the Assessment will also consider the role and capacity of third parties
(such as local and national governments, contractors and suppliers), to the extent that they
pose a risk to the project, recognizing that the client should address these risks and
impacts commensurate to the client’s control and influence over the third party actions.
The impacts associated with supply chains will be considered where the resource utilized
by the project is ecologically sensitive, or in cases where low labor cost is a factor in the
competitiveness of the item supplied. The Assessment will also consider potential
transboundary effects, such as pollution of air, or use or pollution of international
waterways, as well as global impacts, such as the emission of greenhouse gasses.
8. Depending on the type of project and the nature and magnitude of its risks and impacts,
the Assessment may comprise a full-scale social and environmental impact assessment, a
limited or focused environmental or social assessment, or straightforward application of
environmental siting, pollution standards, design criteria, or construction standards. When
the project involves existing business activities, social and/or environmental audits may
need to be performed to determine any areas of concern. The types of issues, risks and
impacts to be assessed, and the scope of the community engagement (see paragraphs 19
through 23 below) can also vary considerably, depending on the nature of the project, and
its size, location, and stage of development.
9. Projects with potential significant adverse impacts that are diverse, irreversible, or
unprecedented will have comprehensive social and environmental impact assessments.
This assessment will include an examination of technically and financially feasible1
alternatives to the source of such impacts, and documentation of the rationale for selecting
the particular course of action proposed. In exceptional circumstances, a regional, sectoral
or strategic assessment may be required.
10. Narrower scopes of Assessments may be conducted for projects with limited impacts
that are few in number, generally site-specific, largely reversible, and readily addressed
through mitigation measures.
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11. Projects with minimal or no adverse impacts will not be subject to further assessment
beyond their identification as such.
12. As part of the Assessment, the client will identify individuals and groups that may be
differentially or disproportionately affected by the project because of their disadvantaged or
vulnerable status.2 Where groups are identified as disadvantaged or vulnerable, the client
will propose and implement differentiated measures so that adverse impacts do not fall
disproportionately on them and they are not disadvantaged in sharing development benefits
and opportunities.
_____________________
1
“Technical feasibility” is based on whether the proposed measures and actions can be implemented with
commercially available skills, equipment and materials, taking into consideration prevailing local factors such as
climate, geography, demography, infrastructure, security, governance, capacity and operational reliability.
“Financial feasibility” is based on commercial considerations, including the relative magnitude of the incremental
cost of adopting such measures and actions compared to the project’s investment, operating and maintenance
costs and whether this incremental cost could make the project nonviable to the client.
2
This status may stem from an individual’s or group’s race, color, sex, language, religion, political or other
opinion, national or social origin, property, birth or other status. The client should also consider factors such as
gender, ethnicity, culture, sickness, physical or mental disability, poverty or economic disadvantage, and
dependence on unique natural resources.
General issues
G8. The process of Social and Environmental Assessment (the Assessment) addresses the
social and environmental impacts and risks (including labor, health, safety, and security) of a
proposed project. It is an important first step in managing and improving project social and
environmental performance, as it helps the client to assess all relevant potential impacts and
risks associated with the project (whether addressed through the Performance Standards or
not), and identify any mitigation or corrective measures that will enable the project to meet the
applicable requirements in Performances Standards 2 through 8, any applicable local laws and
regulations, as well as any additional priorities and objectives for social or environmental
performance identified by the client. For guidance on hard to address labor issues in the
process of, or in addition to, the client’s process of Assessment, see paragraph G4 of Guidance
Note 2. An example of health impact assessment process and critical elements in a health
assessment can be found in Annex C of Guidance Note 4 and its Reference Section. Guidance
on risk assessment related to security issues can also be found in Guidance Note 4.
G9. Even if impacts and risks are not specifically identified in Performance Standards 2
through 8, they should be assessed under Performance Standard 1 as part of the project’s
approach to risk management. For example, all relevant adverse impacts on the livelihoods and
income of the affected communities within the project area of influence should be assessed. Of
such impacts, those that result from project-related land acquisition should be addressed
through Performance Standard 5 on Land Acquisition and Involuntary Resettlement, while other
adverse impacts on livelihoods that result from other project activities should be addressed
under Performance Standard 1. Examples of adverse impacts that should be addressed under
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G10. The Assessment’s key process elements generally consist of (i) project definition;
(ii) (initial) screening of the project and the scoping of the Assessment process; (iii) stakeholder
identification and gathering of social and environmental baseline data, where relevant;
(iv) impact identification and analysis; and; (v) generation of mitigation or management
measures and actions. The breadth, depth and type of analysis should be proportionate to the
nature and scale of the proposed project’s potential impacts as identified during the course of
the Assessment process. The Assessment must conform to the requirements of the host
country’s environmental assessment laws and regulations, including the relevant disclosure of
information and public consultation requirements.
G11. Clients can use in-house staff and/or external consultants or experts to carry out the
Assessment work, provided that the applicable requirements of the Performance Standards are
met. The in-house staff or external personnel conducting the Assessment must be in a position
to do so adequately, accurately and objectively, as well as have the requisite qualifications and
experience. For projects with issues that may pose significant adverse impacts and risks,
clients should consider retaining external experts to assist in the conduct of all or part of the
Assessment. These experts should have relevant and recognized experience in similar projects
and operate independently from those responsible for design and construction. They should be
engaged early in the project’s development phase and, as necessary, in the various stages of
project design, construction, and commissioning. In some high-risk cases, IFC may require a
panel of external experts to advise the client and/or IFC. In addition, external experts are
required in certain defined circumstances, on issues concerning biodiversity (as provided in
paragraph 4 of Performance Standard 6), Indigenous Peoples (as provided in paragraph 11 of
Performance Standard 7) and cultural heritage (as provided in paragraph 4 of Performance
Standard 8).
G12. Early in IFC’s engagement with the client on a prospective project, IFC will review the
stage of development of the project and status of the client’s social and environmental
assessment process and documentation. In many cases, clients will have undertaken some
level of such assessment to satisfy host country requirements or as part of their own corporate
due diligence processes. For specific issues, such as labor and working conditions or the use
of security personnel, the client may have conducted a separate labor assessment or risk
assessment, respectively. These existing documents can be considered as part of the client’s
Assessment consistent with the requirements of Performance Standard 1, as long as key
1
In most countries, surface land rights are legally distinct from sub-surface mineral rights.
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baseline data and assumptions have not materially changed by the time of IFC’s review. Based
on this review, IFC will identify and agree with the client on any additional assessment work that
may be necessary to meet the requirements of Performance Standard 1, the parties responsible
for such assessment, and the timeline for its completion.
Project Definition
G13. The project definition should include a concise description of the proposed project and
its contexts to be assessed. The project description will normally address new facilities or
business activities to be financed by IFC. These facilities are expected to meet the applicable
requirements in Performance Standards 1 through 8 at the outset or, as agreed with IFC, over a
reasonable period of time. If a proposed business activity to be financed by IFC relates to
existing facilities (e.g., restructuring projects, expansions, modernizations, privatizations of such
facilities), IFC will work with the client to develop a management program, including an Action
Plan, that is technically and financially feasible and cost-effective for these facilities to meet the
applicable Performance Standards within a reasonable time frame. Further guidance on project
descriptions can be found in Annex A.
Initial Screening
G14. The initial screening of the project against the applicable local laws and regulations and
the Performance Standards will indicate whether the project may pose social or environmental
risks that should be further analyzed through additional Assessment process steps. It should
identify the extent and complexity of potential impacts and risks in the project’s area of
influence, which is the total area likely to be affected by both on-site and off-site impacts from
project activities (see also paragraph 5 of Performance Standard 1, and paragraphs G18 and 22
below). If the initial screening indicates potential adverse impacts, the scope of the Assessment
should be determined and further impact identification and analysis (based on relevant baseline
data, if any, and considering identified stakeholders) will be necessary to ascertain the nature
and scale of impacts, the affected communities, and possible mitigation measures. Where the
initial screening process concludes that a project will have no or minimal potential adverse
impacts, the client should document this screening process and its conclusions. No further
Assessment or establishment of a Management System will be required.
G15. Stakeholder identification broadly involves the determination of the various individuals or
groups who may have an interest in the project or who may affect or be affected by the project.
The process of stakeholder identification includes distinct steps, including: (i) identifying
individuals, groups or local communities that may be affected by the project, positively or
negatively, and directly or indirectly, making special effort to identify those who are directly
affected, including those who are disadvantaged or vulnerable; (ii) identifying broader
stakeholders who may be able to influence the outcome of the project because of their
knowledge about the affected communities or political influence over them; (iii) identifying
legitimate stakeholder representatives, including elected officials, non-elected community
leaders, leaders of informal or traditional community institutions, and elders within the affected
community; and (iv) mapping the impact zones by placing the affected groups and communities
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within a geographic area, which will help the client define or refine the project’s area of influence
(see paragraph 5 of Performance Standard 1, and paragraphs G18 and 22 below).
G16. The baseline information gathering phase is an important and often a necessary step in
the Assessment process to enable the determination of the potential impacts and risks of a
project. Baseline information gathering should describe the relevant existing conditions, such
as physical, biological, medical and socio-economic. Analysis of project- and site-specific
impacts should be based on current and verifiable primary information. Reference to secondary
information on the project’s area of influence is acceptable, but it may still be necessary to
gather primary information from field surveys to establish baselines appropriate to the proposed
project’s potential impacts and risks. Relevant data may be available from various host
governmental, NGO and academic studies. However, clients should carefully evaluate data
sources and potential data gaps. Accurate and up-to-date baseline information is essential, as
rapidly changing situations, such as in-migration of people in anticipation of a project or
development 2, or lack of data on disadvantaged or vulnerable individuals and groups within an
affected community, can seriously affect the efficacy of social mitigation measures. Limitations
on data, such as the extent and quality of available data, assumptions and key data gaps, and
uncertainties associated with predictions, should be clearly identified.
G17. Potential impacts and risks should be assessed and documented for each key stage of
the project cycle including design and planning, construction, operations, and decommissioning
or closure and for their short-term, long-term, and cumulative contexts (see paragraph G22
below), keeping in mind the dynamic and shifting nature of these impacts and risks.
G18. The size of a project’s area of influence and the social and environmental impacts and
risks within the area can vary considerably. Some of these impacts and risks, particularly those
described in the Performance Standards, may be attributable to third parties within the area of
influence. The larger the area of influence, the more likely that third party action or non-
performance could pose risks to projects. Where relevant, the Assessment includes these third
party risks, particularly risks over which the client may have a degree of control or influence.
G19. In addition to adverse impacts and risks, the Assessment can assess potential positive
or beneficial impacts of a project and propose measures to enhance them. These measures
can be implemented through the client’s social and environmental management program. If
requested by clients, IFC can assist clients to enhance the positive outcomes of the project
through various technical and financial assistance and programs.
Global Impacts
G20. While individual project impacts on climate change, ozone layer, biodiversity or similar
environmental issues may not be significant, when taken together with impacts created by other
human activities, they can become nationally, regionally or globally significant. When a project
2
In–migration can pose significant impacts on host communities. Demographic surveillance systems that can
accurately track community level influx have been established in many settings and there are established
methodologies that can be readily consulted (for examples, see the References Section).
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has the potential for large scale impacts that can contribute toward adverse global
environmental impacts, the Assessment should consider these impacts. Specific requirements
and guidance on greenhouse gases and ozone-depleting substances can be found in
Performance Standard 3 and its accompanying Guidance Note, and on biodiversity, in
Performance Standard 6 and its accompanying Guidance Note.
Transboundary Impacts
G21. Transboundary impacts are impacts that extend to multiple countries, beyond the host
country of the project, but are not global in nature. Examples include air pollution extending to
multiple countries, use or pollution of international waterways 3, and transboundary epidemic
disease transmission 4. If the Assessment determines that: (i) the project entails activities that
may cause adverse effects through air pollution or abstraction of water from or pollution of
international waterways; (ii) the affected countries and the host country have entered into any
agreements or arrangements or have established any institutional framework regarding the
potentially affected airshed, waterway, subsurface water, or other resources; or (iii) there are
unresolved differences between the affected and host countries regarding the potentially
affected resource, and the likelihood of a resolution is not imminent, the client may be required
to provide notice of the proposed project to the affected country or countries. When requested
by the client, IFC will assist the client with notifying competent authorities of the affected
countries. IFC’s role in this regard is outlined in paragraph 40 of the IFC Policy on Social and
Environmental Sustainability (Sustainability Policy). IFC’s procedure for notification of
competent authorities can be found in the Environmental and Social Review Procedure.
Examples of regional systems of assessment and notification of transboundary impacts can be
found in the References section.
Cumulative Impacts
G22. The combination of multiple impacts from existing projects, the proposed project, and/or
anticipated future projects may result in significant adverse and/or beneficial impacts that would
not be expected in case of a stand-alone project. The Assessment should evaluate these
cumulative impacts commensurate with the source, extent, and severity of cumulative impacts
anticipated. As a result, the geographic and temporal boundaries of the cumulative impact
assessment would depend on the potential cumulative impacts that are attributable to the
project and those that affect the project as a result of reasonably foreseeable activities by third
3
IFC defines an international waterway as: (a) any river, canal, lake, or similar body of water that forms a boundary
between, or any river or body of surface water that flows through, two or more states, whether IFC members or not;
(b) any tributary or other body of surface water that is a component of any waterway described in (a) above; and (c)
any bay, gulf, strait, or channel bounded by two or more states or, if within one state, recognized as a necessary
channel of communication between the open sea and other states--and any river flowing into such waters.
4
Transboundary epidemic disease transmission is well known and has been observed in many settings. Many
infectious diseases, such as cholera, influenza and meningitis, can be rapidly and easily spread across national
borders, particularly when a project attracts a large influx of potential job seekers during a construction phase.
Similarly, a project may bring in large numbers of overseas workers for short-term specialty construction work. In
some situations, the disease spectrum of the imported workers may be quite different than the host country, e.g.,
multi-drug resistant tuberculosis, vivax versus falciparum forms of malaria. In some cases, it may be appropriate for
very large scale transboundary projects to consider the potential for global or regional level disease epidemic
transmission, e.g., avian influenza and SARS.
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parties, and will influence the final definition of the project area of influence. Examples of
cumulative impacts include ambient conditions in an airshed (see paragraph 9 of Performance
Standard 3), conditions in a watershed, or secondary or induced social impacts, such as in-
migration or substantially increased transport activity in a project area of influence (see
paragraphs G5, G22, and G23 of Guidance Note 4). The client’s baseline study should identify
any relevant existing project or condition. In terms of anticipated future projects, priority should
be given to assessing cumulative impacts stemming from the proposed project, such as further
planned development of the project and other project-related future developments that are
realistically defined at the time of the Assessment (for example, an anticipated future
development for which licenses or permits have been issued should be included, even if it is not
yet in implementation). IFC will work with the client to identify existing data and studies, and if
necessary will consider available technical and financial assistance mechanisms on a case-by-
case basis. In situations where cumulative impacts are likely to occur from activities by third
parties in the project region, a regional or sectoral assessment may be appropriate. It may not
be feasible for the client to undertake such a study, for example, in situations where the impacts
from the client’s own operations are expected to be a relatively small amount of the cumulative
total. For further guidance on such assessments, see paragraph G31 and 32 below. While the
client is responsible for gathering information on cumulative impacts under paragraph 5 of
Performance Standard 1, paragraph 6 of the Performance Standard also indicates that the client
is expected to address risks and impacts commensurate to the client’s control and influence
over third party actions.
Human Rights
G23. A number of international agreements and conventions have established basic human
rights (a list of these international instruments can be found in the References section of
Guidance Note 2; other useful guidance supporting human rights can be found in the
References section of Guidance Notes 3, 4, 5, and 7). While states are responsible for
protecting these human rights, it is increasingly expected that private sector companies conduct
their affairs in a way that would uphold these rights and not interfere with states’ obligations
under these instruments. In addition, business conduct that is inconsistent with these basic
human rights can pose risks to business, and as a result, the Assessment process is a useful
tool to analyze these risks and to consider management measures. Descriptions of some of
these risks can be found in Performance Standards 2, 3, 4, 5 and 7. IFC recently released a
draft of the Guide to Human Rights Impact Assessment and Management (Guide to HRIA)
jointly developed by IFC and the International Business Leaders Forum. The draft Guide to
HRIA was released to enable voluntary road-testing of the HRIA by a number of companies. If
human rights are likely to be a significant and specific risk for the project, companies can
consider carrying out an HRIA along with the Social and Environmental Assessment.
G24. There may be individuals or groups within the project area of influence who are
particularly vulnerable or disadvantaged and who could experience adverse impacts from the
proposed project more severely than others, as described in footnote 2 of Performance
Standard 1. Large scale projects with a large project area of influence and multiple affected
communities are more likely to expose these individuals and groups to adverse impacts than
smaller scale projects with site specific issues. Where it is anticipated that the project will
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impact one or more affected communities, the Assessment process should use accepted
sociological and health methods to identify and locate vulnerable individuals or groups within the
affected community population, collecting data on a disaggregated basis. Using this
disaggregated information, the client should assess potential impacts, including differentiated
impacts, on these individuals and groups and propose specific (and if necessary separate)
measures in consultation with them to ensure that potential impacts and risks to them are
appropriately avoided, mitigated or compensated. Vulnerable or disadvantaged individuals and
groups should be able to benefit from project opportunities equally with the rest of the affected
community; this may require that differentiated benefit-sharing processes and levels (such as
ensuring that compensation for a house taken during resettlement is provided equally to the
woman and man of the household, providing training for individuals or groups who might lack
the necessary skills to find a job with the project, ensuring access to medical treatments for
medial conditions resulting from the project, etc.) are available. Project monitoring should track
these individuals or groups on a disaggregated basis. Specific considerations and measures for
Indigenous Peoples are described in Performance Standard 7 and the accompanying Guidance
Note. Clients should exercise discretion in gathering personal data and information and should
treat such data or information as confidential (except where disclosure is required by law).
Where Performance Standard 1 requires disclosure of plans based on personal info or data
collected, (such as a resettlement action plan) the client should ensure that any personal data or
information cannot be associated with particular individuals.
Disability
G25. There are country laws, regulations, and other guidance pertaining specifically to people
with disabilities, who are highly vulnerable to disproportionate impact from projects. Where no
adequate legal framework exists, the client should identify appropriate alternatives to avoid,
minimize, mitigate, or compensate for potential adverse impacts and risks on people with
disabilities. The alternatives should be focused on creating access to the resources and
services for the community (e.g., accessibility to education, medical assistance, training,
employment, tourism, and consumer goods; and physical accessibility to transportation,
schools, hospitals/clinics, work facilities, hotels, restaurants, stores, and other commercial
areas). See the References Section for A Design Manual for a Barrier Free Environment, and
The U.S. Access Board. Clients should also consider incorporating the principles of universal
design (defined as the design of products, environments, programmes and services to be
usable by all people, to the greatest extent possible, without the need for adaptation or
specialized design 5) into project design, construction, and operation (including emergency and
evacuation plans), whether new construction or restructuring, expansion, or modernization of
facilities, to maximize use by all potential users, including people with disabilities.
Gender
G26. A project may have different impacts on women and men, due to their differentiated
socioeconomic roles and their varying degrees of control over and access to assets, productive
5
“Universal design” shall not exclude assistive devices for particular groups of persons with disabilities where this is
needed (Article 2 of the United Nation Convention on the Rights of Persons with Disabilities adopted December 13,
2006)
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resources, and employment opportunities. There may be norms, societal practices, or legal
barriers that impede the full participation of persons of one gender (usually women, but
potentially men) in consultation, decision-making, or sharing of project benefits. These legal
and societal norms and practices may lead to gender discrimination or inequality. Gender-
differentiated impacts should be assessed and the Assessment should propose measures
designed to ensure that one gender is not disadvantaged relative to the other in the context of
the project. This may include providing opportunities to enhance full participation and influence
in decision-making through separate mechanisms for consultation and grievances, and
developing measures that allow both women and men equal access to project benefits (such as
land titles, compensation, and employment).
G27. Health performance indicators and gender are strongly associated with each other.
Demographic Health Surveys (DHS) have repeatedly demonstrated the profound connection
between gender (usually women) and a wide variety of key health performance indicators.
Proposed interventions should be sensitive to and aware of the unique role played by women in
health. The use of peer educators and community level women’s organizations should be
considered. In many developing country settings, there are marked differences in the literacy
and educational attainment levels of women. Typically, female literacy and educational
attainment levels are marked lower than men, even if the woman is the household head.
Household level education literacy/attainment is also strongly tied to many critical health
performance indicators. Therefore, proposed mitigation interventions and/or outreach efforts
must factor this “education gap” into the planning process.
G28. The client may have limited or no leverage on third parties, such as a government
agency in charge of controlling in-migration in the project area, or an illegal logging operation
taking advantage of project access roads through forests. Nonetheless, the project description
in the Assessment report should encompass facilities and activities by third parties that are
essential for the successful operation of the project, and the Assessment process for a project
with a large area of influence should identify the roles of third parties and the potential impacts
and risks from their actions or non-performance. Clients should collaborate with third parties
and take action to the extent of their influence or control over them. IFC will work with the client
on a case-by-case basis to have the client and, where feasible, third parties develop appropriate
mitigation strategies.
G29. Among these third parties are operators of associated facilities (see item (ii) in
paragraph 5 of Performance Standard 1) that may have a particularly close relationship with the
project. Because of this relationship, the client will normally have some commercial leverage on
the operators of such facilities. Where such leverage allows, undertakings can be secured from
these operators to operate their facilities consistent with the applicable Performance Standards.
In addition, the client should identify its own actions, if any, that will support or supplement the
actions of the associated facilities.
G30. As with the third party impacts and risks described above, projects’ relationships with
supply chains could pose a particular challenge in certain sectors. The Assessment should
identify the roles, impacts and risks of key suppliers in relation to labor issues and ecologically
sensitive resources, as described in paragraph 6 of Performance Standard 1. Generally, where
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the client has commercial leverage over its suppliers, IFC will expect the client to work with its
suppliers to propose mitigation measures proportionate to identified risks on a case-by-case
basis, while recognizing that assessing and addressing supply chain implications beyond the
first or the second tier suppliers would not be practical or meaningful to the client or the supplier.
Additional information on addressing labor issues of the client’s key suppliers, particularly those
related to child labor and forced labor, can be found in paragraph 18 of Performance Standard 2
and the accompanying guidance. For biodiversity issues in the supply chain, see Performance
Standard 6 and the accompanying Guidance Note.
G32. When the need for such assessments is indicated, IFC will work with the client to identify
existing data and studies already carried out by other institutions, such as the World Bank, other
multilateral financial institutions and/or national agencies. In the absence of such data or
studies, IFC will assist the client to identify the appropriate terms of reference for such
assessments, and will consider available technical and financial assistance mechanisms.
Mitigation Measures
G33. If the impact analysis confirms potential impacts and risks, clients should develop
measures and actions to avoid, minimize, mitigate, compensate for, or offset potential adverse
social and environmental impacts, or, in case of positive or beneficial impacts, to enhance them.
As a general principle for adverse social and environmental impacts, the Assessment should
focus on measures to prevent these from occurring in the first place, as opposed to
minimization, mitigation, or compensation. At the same time, however, IFC recognizes this can
pose challenges for projects, and that measures should be drawn from options that are
technically and financially feasible (as defined in footnote 1 of Performance Standard 1) and
cost effective (as defined in footnote 2 of Performance Standard 3). Where trade-offs between
avoidance and mitigation/compensation are considered, these should be documented. The
Assessment should consider economic, financial, environmental and social costs and benefits
and identify to which parties these accrue. The costs and benefits may be expressed in
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qualitative or quantitative terms, and the analysis of the balance between costs and benefits
should be explained. Where these impacts are within the client’s capacity to control or
influence, the client should capture the mitigation or corrective measures in a management
program or the Action Plan (see paragraphs 13 through 16 of Performance Standard 1 and the
accompanying Guidance Notes) and implement these through the Management System.
G34. The outcome of the Assessment process should be documented. The assessment
process may result in one or more documents with separate analysis, particularly when the
client engages various experts to address multiple Performance Standards.
G35. Projects with limited adverse impacts and risks, both new projects and those involving
existing facilities (the type of projects likely to be considered as Category B projects by IFC),
need documentation on the screening process, impacts analysis, proposed mitigation
measures, and the process of disclosure of information, and community engagement (if there
are affected communities). At a minimum, clients should have one or more documents or
analysis that describe:
G36. If early analysis for the Assessment identifies potentially significant adverse social and
environmental impacts and risks that are diverse, irreversible, or unprecedented (the type of
projects likely to be considered as Category A projects by IFC), a formal social and
environmental impact assessment report will be prepared in accordance with accepted
international practice, and consistent with Annex A. For these projects, summaries of analyses
should explain findings clearly and objectively, and be understandable to laypersons. For those
projects with potentially significant adverse impacts predominantly in the social area (e.g.,
involuntary resettlement), the Assessment process should largely focus on generating
appropriate social baseline data, impacts analysis, and mitigation measures (e.g., Resettlement
Action Plan).
G37. These projects will normally need to conduct an alternatives analysis as part of the
social and environmental assessment. The purpose of alternative analysis is to improve project
design, construction, and operation decisions based on feasible project alternatives. This
analysis may facilitate the consideration of social and environmental criteria at the early stages
of project development and make decisions based on the differences between real choices.
The alternatives analysis should be conducted as early as possible in the Assessment process
and examine feasible alternatives such as alternative project locations, designs or operational
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processes, or alternative ways of dealing with social and environmental impacts. The analysis is
subject to the disclosure and consultation requirements of the Assessment. Additional
information regarding the analysis of alternatives is provided in Annex A.
G38. When projects involve existing facilities, environmental and social audit reports and
hazard/risk assessment reports should be prepared in accordance with accepted international
practice and follow the table of contents provided in Annex B.
Management Program
13. Taking into account the relevant findings of the Social and Environmental Assessment
and the result of consultation with affected communities, the client will establish and
manage a program of mitigation and performance improvement measures and actions that
address the identified social and environmental risks and impacts (the management
program).
15. The program will define desired outcomes as measurable events to the extent possible,
with elements such as performance indicators, targets, or acceptance criteria that can be
tracked over defined time periods, and with estimates of the resources and responsibilities
for implementation. Recognizing the dynamic nature of the project development and
implementation process, the program will be responsive to changes in project
circumstances, unforeseen events, and the results of monitoring (see paragraph 24 below).
G39. The level of detail and complexity of the management program should be commensurate
with the project’s anticipated impacts and risks. Where a Social and Environmental Impact
Assessment format is required as described in paragraph 9 of Performance Standard 1, the
management program should include an Action Plan as described in paragraph 16 of
Performance Standard, and contain the measures listed under the heading “Management
Program” in Annex A. For projects with limited potential impacts, the management program
should address those limited impacts, and are likely to be less elaborate. In the case of existing
facilities, the management program is likely to include corrective measures and an Action Plan
to address areas of improvement identified in the social and environmental audit. As part of the
management program, the client may wish to establish its own internal performance measures
so as to enhance positive project impacts and the desired outcomes as measurable events to
the extent possible. These include measures such as performance indicators, targets, or
acceptance criteria that can be tracked over defined time periods, to ensure continuous
improvement of performance in these areas.
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G40. The management program should be implemented through the client’s Social and
Environmental Management System (see paragraph 3 of Performance Standard 1 and the
accompanying guidance), so that it will enable the client to determine adequate allocation of
financial resources and designation of responsible personnel within the client’s organization,
and to implement as part of overall site, project or corporate management.
Action Plan
16. Where the client identifies specific mitigation measures and actions necessary for the
project to comply with applicable laws and regulations and to meet the requirements of
Performance Standards 1 through 8, the client will prepare an Action Plan. These measures
and actions will reflect the outcomes of consultation on social and environmental risks and
adverse impacts and the proposed measures and actions to address these, consistent with
the requirements under paragraph 21. The Action Plan may range from a brief description
of routine mitigation measures to a series of specific plans.3 The Action Plan will: (i)
describe the actions necessary to implement the various sets of mitigation measures or
corrective actions to be undertaken; (ii) prioritize these actions; (iii) include the time-line for
their implementation; (iv) be disclosed to the affected communities (see paragraph 26); and
(v) describe the schedule and mechanism for external reporting on the client’s
implementation of the Action Plan.
_____________________
3
For example, Resettlement Action Plans, Biodiversity Action Plans, Hazardous Materials Management Plans,
Emergency Preparedness and Response Plans, Community Health and Safety Plans, and Indigenous Peoples
Development Plans.
G41. Taking the result of the Social and Environmental Assessment process, including the
result of consultation during this process (see paragraphs 19 through 23 of Performance
Standard 1 and the accompanying Guidance Notes), the client should prepare its Action Plan,
which is a part of the management program focusing on the measures and actions necessary
for the client to comply with applicable national laws and regulations and to meet the
requirements of the applicable Performance Standards. It can exclude information that is of an
internal nature, such as proprietary information, cost data, information that would compromise
project site security and safety, and detailed procedures, business processes, and instructions
for workers (which should be included in the management program). As part of its ongoing
engagement with affected communities, the client is required to disclose its Action Plan in
advance of project implementation to affected communities and stakeholders, and provide
updates throughout the life of the project as mitigation measures are adjusted and upgraded,
reflecting the feedback from the affected communities.
Organizational Capacity
17. The client will establish, maintain, and strengthen as necessary an organizational
structure that defines roles, responsibilities, and authority to implement the management
program, including the Action Plan. Specific personnel, including management
representative(s), with clear lines of responsibility and authority should be designated. Key
social and environmental responsibilities should be well defined and communicated to the
relevant personnel and to the rest of the organization. Sufficient management sponsorship
and human and financial resources will be provided on an ongoing basis to achieve
effective and continuous social and environmental performance.
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G42. The successful implementation of the management program, including the Action Plan,
calls for the commitment of management and workers of the client’s organization. Accordingly,
the client should designate specific in-house personnel, including management
representative(s), with clear lines of responsibility and authority for social and environmental
issues. If functions are outsourced to contractors, the client’s agreement with the contractors
should include actions and measures necessary for the parties to perform the agreement
consistent with the management program. In large or complex organizations multiple personnel
or operational units may be designated. In small or medium-sized enterprises, these
responsibilities may be undertaken by one individual. It is also important that the key social and
environmental responsibilities are well defined and communicated to the relevant personnel and
the rest of the organization. Appropriate human and financial resources should be allocated to
those designated as responsible for the implementation of the management program and any
additional performance measures. Annex C contains a series of questions that may be useful
for clients to pose to assess adequacy of its capacity and process.
Training
18. The client will train employees and contractors with direct responsibility for activities
relevant to the project’s social and environmental performance so that they have the
knowledge and skills necessary to perform their work, including current knowledge of the
host country’s regulatory requirements and the applicable requirements of Performance
Standards 1 through 8. Training will also address the specific measures and actions
required under the management program, including the Action Plan, and the methods
required to perform the action items in a competent and efficient manner.
G43. The management program should identify the knowledge and skills necessary for its
implementation, including implementation of the Action Plan. These should be considered in
personnel selection, training, skills development, on-going education, and new recruitment if
necessary. Training programs typically have the following elements:
G44. Training relevant to implementing specific action items in the management program may
be necessary. Training designed to help the employees gain appropriate knowledge base and
skills to perform their work may include current knowledge of host country regulatory
requirements, the applicable requirements of Performance Standards 2 through 8, the material
impacts predicted through the Assessment process, the content of the management program,
including the Action Plan, and the methods required to perform the action items in a competent
and efficient manner. When a project is likely to impact vulnerable or disadvantaged individuals
or groups within affected communities, employees who will interact with such individuals or
groups should be trained so that they understand the specific issues related to such individuals
or groups.
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G45. When specific aspects of the project or the implementation of the management program
are outsourced to contractors, the client should also ensure that these contractors have the
requisite knowledge, skills, and training to perform the work in accordance with the
management program and the requirements of Performance Standards 2 through 8, consistent
with the guidance in paragraph G44 above.
Community Engagement
19. Community engagement is an on-going process involving the client’s disclosure of
information. When local communities may be affected by risks or adverse impacts from a
project, the engagement process will include consultation with them. The purpose of
community engagement is to build and maintain over time a constructive relationship with
these communities. The nature and frequency of community engagement will reflect the
project’s risks to and adverse impacts on the affected communities. Community
engagement will be free of external manipulation, interference, or coercion, and
intimidation, and conducted on the basis of timely, relevant, understandable and accessible
information.
Disclosure
20. Disclosure of relevant project information helps affected communities understand the
risks, impacts and opportunities of the project. Where the client has undertaken a process
of Social and Environmental Assessment, the client will publicly disclose the Assessment
document. If communities may be affected by risks or adverse impacts from the project, the
client will provide such communities with access to information on the purpose, nature and
scale of the project, the duration of proposed project activities, and any risks to and
potential impacts on such communities. For projects with adverse social or environmental
impacts, disclosure should occur early in the Social and Environmental Assessment
process and in any event before the project construction commences, and on an ongoing
basis (see paragraph 26 below).
Consultation
21. If affected communities may be subject to risks or adverse impacts from a project, the
client will undertake a process of consultation in a manner that provides the affected
communities with opportunities to express their views on project risks, impacts, and
mitigation measures, and allows the client to consider and respond to them. Effective
consultation: (i) should be based on the prior disclosure of relevant and adequate
information, including draft documents and plans; (ii) should begin early in the Social and
Environmental Assessment process; (iii) will focus on the social and environmental risks
and adverse impacts, and the proposed measures and actions to address these; and (iv) will
be carried out on an ongoing basis as risks and impacts arise. The consultation process
will be undertaken in a manner that is inclusive and culturally appropriate. The client will
tailor its consultation process to the language preferences of the affected communities,
their decision-making process, and the needs of disadvantaged or vulnerable groups.
22. For projects with significant adverse impacts on affected communities, the consultation
process will ensure their free, prior and informed consultation and facilitate their informed
participation. Informed participation involves organized and iterative consultation, leading
to the client’s incorporating into their decision-making process the views of the affected
communities on matters that affect them directly, such as proposed mitigation measures,
the sharing of development benefits and opportunities, and implementation issues. The
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client will document the process, in particular the measures taken to avoid or minimize risks
to and adverse impacts on the affected communities.
Grievance Mechanism
23. The client will respond to communities’ concerns related to the project. If the client
anticipates ongoing risks to or adverse impacts on affected communities, the client will
establish a grievance mechanism to receive and facilitate resolution of the affected
communities’ concerns and grievances about the client’s environmental and social
performance. The grievance mechanism should be scaled to the risks and adverse impacts
of the project. It should address concerns promptly, using an understandable and
transparent process that is culturally appropriate and readily accessible to all segments of
the affected communities, and at no cost and without retribution. The mechanism should
not impede access to judicial or administrative remedies. The client will inform the affected
communities about the mechanism in the course of its community engagement process.
G47. If the Assessment process indicates that there may be potential impacts and risks to the
communities within the project’s area of influence, companies should seek early engagement
with these affected communities. Engagement should be based on the timely dissemination of
relevant project information, including the social and environmental impacts and risks of the
project identified in the Assessment and proposed mitigation measures, in languages and
methods preferred by the affected communities. In cases where the Assessment has been
completed prior to IFC involvement in a project, IFC reviews the process of community
engagement carried out by the client. If necessary, IFC and the client will agree on a
supplemental community engagement program.
Disclosure of Information
G48. Information disclosure involves delivering information about the project to the affected
communities and other stakeholders. The information should be in appropriate language(s). It
should be made accessible and understandable to the various segments of the affected
communities, in ways appropriate to the community. For example, information can be made
available in city halls, public libraries, in the local print media, over the radio, or in public
meetings. The timing and the method of disclosure will vary depending on national law
requirements, the type of Assessment involved, and the stage of the project’s development or
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operation. As a minimum, the client should disclose the final Assessment document and the
Action Plan prior to the commencement of construction or other implementation activities. In
some cases, disclosure of information will occur earlier in the Assessment process. For projects
with potential adverse impacts to communities, timely disclosure of information should occur
after the initial screening, and should include information on the purpose, nature and scale of
the project, the duration of proposed project activities, and any risks to and potential impacts on
such communities. Such disclosure may be achieved by disclosing a draft Assessment
document. In addition, it may also be appropriate for the client to disclose a draft Action Plan so
that the measures proposed by the client to mitigate the identified risks and impacts can be
explained. Disclosure of information will be the basis of the client’s consultation process (see
paragraphs 21 and 22 of Performance Standard 1 and the accompanying guidance).
G49. Disclosure of information is normally expected as part of the Assessment process, but if
the project is expected to create ongoing impacts and risks to the affected communities, the
client should continue to provide information about the project during the life of the project. The
client’s reporting requirements to the affected community are addressed in paragraph 26 of
Performance Standard 1 and the accompanying guidance. The client may disclose information
on non-financial issues or opportunities for enhancing social and environmental impacts through
sustainability reports, as described in paragraph G67 below.
G50. In the extractive industries and infrastructure sectors in particular, where a project can
have potentially broader implications for the public at large, disclosure of information is an
important means to manage governance risks. Accordingly, clients should be aware that IFC
has sector-specific initiatives on disclosure of project-related information, as described in
paragraphs 21 through 23 of IFC's Sustainability Policy. Further guidance on the Extractive
Industries Transparency Initiative and how the private sector can support this initiative can be
found in the References section.
Consultation
G51. Consultation involves two-way communication between the client and the affected
communities. Effective consultation provides opportunities for the client to learn from the
experience, knowledge, and concerns of the affected communities, as well as to manage
community expectations by clarifying the extent of its responsibilities and resources so that
misunderstandings and unrealistic demands can be avoided. For the consultation process to be
effective, project information needs to be disclosed and explained to the communities, and
sufficient time should be allocated for them to consider the issues. Consultation should be
inclusive of various segments of the affected community, including both women and men, and
accessible to the disadvantaged and vulnerable groups within the community. Based on an
earlier preliminary stakeholder analysis, the client’s representatives should meet with the
affected communities and explain the project information, answer questions and listen to
comments and suggestions. In addition to community meetings open to members of the
affected communities, the client should identify community leaders and any formal or informal
existing decision-making mechanisms so that their input can be sought.
G52. Some projects may not require a process of consultation, unless community members
seek to engage with the client on disclosed project information or raise grievances.
Consultation should be undertaken in most situations where the project presents a specific but
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limited number of potential adverse impacts to affected communities. In these cases, the client
should consult with the affected communities during the process of Assessment after the risks
and impacts have been identified and analyzed. In the case of projects with significant adverse
impacts on affected communities, and projects with adverse impacts on Indigenous Peoples,
the process of free, prior, and informed consultation and informed participation is required (see
paragraph G53 below). In addition to the requirements in Performance Standard 1,
requirements on consultation can be found in Performance Standards 4, 5, 6, 7, and 8.
G53. For projects with significant potential adverse impacts to the affected communities, the
client’s consultation process will include their free, prior and informed consultation and informed
participation. Such consultation should be “free” (free of intimidation or coercion), “prior” (timely
disclosure of information) and “informed” (relevant, understandable and accessible information),
and should continue through the entire life of the project and not only during the early stages of
the project. Consultation with affected communities should be part of the early scoping process
that establishes the terms of reference for the Assessment process, which includes an inventory
of risks and impacts to be assessed. Informed participation entails organized and iterative
consultation on issues concerning potential impacts to the affected communities, so that the
client can incorporate into their decision-making process their views on these issues. Free,
prior, and informed consultation and informed participation are also required for projects with
potential adverse impacts to Indigenous Peoples (see Performance Standard 7). The client
should document specific actions, measures or other instances of decision-making that have
been influenced by or resulted directly from the input of those who participated in the
consultation. Annex D describes the type of information IFC will seek from its client during its
social and environmental review to ascertain that the client’s process of community engagement
involves the free, prior, and informed consultation of the affected communities.
G54. As outlined in paragraphs 19 and 20 of the IFC Sustainability Policy, IFC will review the
client’s community engagement process and, through its own investigation, assure itself that
there was free, prior, and informed consultation and informed participation, leading to broad
community support for the project by the affected communities. IFC will make this investigation
when a project may pose significant adverse impacts to local communities, or in the case of
communities of Indigenous Peoples, adverse impacts on such communities. Broad community
support is a collection of expressions by the affected communities, through individuals and their
recognized representatives, in support of the project. There may be broad community support
even if some individuals or groups object to the project. IFC’s inquiry on the existence of free,
prior and informed consultation and broad community support is an inquiry on the overall
engagement process of the client. This inquiry is not intended to establish any consent or veto
right for the affected communities. IFC’s Environmental and Social Review Procedure
describes the type of information IFC will seek to ascertain that the client’s process of free, prior,
and informed consultation led to the broad community support for the project within the affected
communities. After the Board approval of the project, IFC will continue to monitor the client’s
community engagement process as part of its portfolio supervision.
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G55. IFC encourages clients with high-risk projects to also identify and engage with other
stakeholders, beyond those who will be affected by the project, such as local government
officials, community leaders and civil society organizations, particularly those who work in or
with the affected communities. While these groups may not be directly affected by the project,
they may have the ability to influence or alter the relationship of the client with affected
communities, and in addition may play a role in identifying risks, potential impacts and
opportunities for the clients to consider and address in the Assessment process.
Ongoing Engagement
G56. Throughout the life of the project, clients should build upon the channels of
communication and engagement with affected communities established during the Assessment
process. In particular, clients should use the appropriate community engagement practices
described in Performance Standard 1 to disclose information and receive feedback on the
effectiveness of the implementation of the mitigation measures in the Action Plan as well as the
affected communities’ ongoing interests and concerns about the project.
Grievance Mechanism
G58. Except in the simplest cases, the client should establish a procedure for receiving,
addressing, and recording/documenting complaints. This procedure should clearly define who
can raise complaints, and ensure that the confidentiality of the persons raising the complaint is
protected. It should also be easily accessible and understandable to the members of the
affected community and should be communicated to the affected community. The client may
wish to seek solutions to complaints in a collaborative manner with the involvement of the
affected communities. If the project is unable to solve a complaint, it may be appropriate to
enable complainants to have recourse to external experts or neutral parties. Clients should be
aware of judicial and administrative mechanisms available in the country for resolution of
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disputes, and should not impede access to these mechanisms. Grievances received and
responses provided should be documented (such as the name of the individual or organization;
the date and nature of the complaint; any follow up actions taken; the final decision on the
complaint; how and when relevant project decision was communicated to the complainant; and
whether management action has been taken to avoid recurrence of community concerns in the
future), and reported back to the affected communities periodically. In addition to the
requirements in Performance Standard 1, specific requirements for grievance mechanisms can
be found in Performance Standards 2, 4, 5, and 7. For additional guidance on grievance
mechanisms, see IFC’s publication Stakeholder Engagement: A Good Practice Handbook for
Companies Doing Business in Emerging Markets.
Monitoring
24. As an element of its Management System, the client will establish procedures to
monitor and measure the effectiveness of the management program. In addition to
recording information to track performance and establishing relevant operational controls,
the client should use dynamic mechanisms, such as inspections and audits, where relevant,
to verify compliance and progress toward the desired outcomes. For projects with
significant impacts that are diverse, irreversible, or unprecedented, the client will retain
qualified and experienced external experts to verify its monitoring information. The extent
of monitoring should be commensurate with the project’s risks and impacts and with the
project’s compliance requirements. Monitoring should be adjusted according to
performance experience and feedback. The client will document monitoring results, and
identify and reflect the necessary corrective and preventive actions in the amended
management program. The client will implement these corrective and preventive actions,
and follow up on these actions to ensure their effectiveness.
G59. Monitoring is the client’s primary means for tracking and evaluating progress towards the
implementation of action items specified in the Action Plan and other aspects of the
management program. Clients should establish a system for measuring and monitoring
consisting of: (i) the key impacts of the project on workers, communities and the natural
environment as identified by the Assessment; (ii) compliance with laws and regulations; and (iii)
monitoring progress with the implementation of the management program. The extent of
monitoring should be commensurate with the potential impacts and risks of the project as
identified by the Assessment, and as specified in the management program. In addition,
depending on the project, it may be appropriate for the client to establish, track and measure
key indicators and other performance measures over time to improve the project’s performance.
G60. Social monitoring programs may be established to enhance the effective follow-up of
social issues identified in the Assessment and to respond to on-going issues from operations
identified through assessment of these issues. As part of the monitoring programs established
in the management program, it would be appropriate for the client to establish key social
development measurements and indicators, quantitative and qualitative measures of success,
or community engagement practices included in the Action Plan in order to improve
performance on social issues identified in the Assessment process.
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should be commensurate with the risk of the pollutant releases as related to the sensitivity of the
surrounding areas, taking into account the affected community’s perception of project risks to
their health and environment. Appropriate processes should also be in place to ensure the
reliability of data, such as calibration of instruments, test equipment, and software and hardware
sampling. Specific environmental monitoring measures comprise the parameters to be
measured, methods to be used, sampling locations, frequency of measurements, detection
limits (where appropriate), and the definition of thresholds that signal the need for corrective
actions.
G62. Monitoring results should be documented, and the necessary corrective and preventive
actions identified. Clients should also ensure that these corrective and preventive actions have
been implemented and that there is a systematic follow-up to ensure their effectiveness. The
client should normally carry out the monitoring using its internal resources, as part of its
management program. For projects with significant adverse impacts that are diverse,
irreversible, unprecedented, the client will retain qualified and experienced external experts to
verify its monitoring information. Participatory monitoring (i.e. involvement of affected
communities and other stakeholders) should be considered for large, high-risk projects. In
these cases, the client should evaluate the capacity of those participating in the monitoring and
provide periodic training and guidance as appropriate.
G63. The outcome of monitoring may indicate that the mitigation measures in the
management program should be adjusted or upgraded. As part of on-going maintenance of its
Management System, the client should update the management program from time to time, so
that it can adequately address the change in the social or environmental risks arising from any
change in the client’s business or circumstances.
Reporting
Internal Reporting
25. Senior management in the client organization will receive periodic assessments of the
effectiveness of the management program, based on systematic data collection and
analysis. The scope and frequency of such reporting will depend upon the nature and
scope of the activities identified and undertaken in accordance with the client’s
management program and other applicable project requirements.
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G64. The results of social and environmental monitoring should be evaluated and
documented. Periodic reporting of progress and monitoring results should be made to the
senior management of the client’s organization, as a function of the client’s management
system. Reports should furnish the information and data needed to determine compliance with
relevant host country legal requirements and progress on implementing the management
program. The format of these reports can vary according to the nature of the organization, but
should include summary of findings and recommendations. This information should also be
made available broadly within the client’s organization and the relevant workers as appropriate.
G65. As part of IFC’s ongoing review of portfolio projects, IFC requires its clients to submit
Monitoring Reports on social and environmental performance pursuant to the project’s
management program, including the Action Plan and any other key social and environmental
criteria. The format and frequency of the Monitoring Reports to IFC will be initially agreed with
the client. Reporting formats can vary according to project circumstances, and can be based on
the existing formats used by the client to prepare internal or external reports. Monitoring reports
will normally be on an annual basis unless IFC and the client agree otherwise. The Monitoring
Reports should contain sufficient data and descriptive information to enable IFC to track the
project’s progress on implementing the management program and the Action Plan. IFC’s
procedural requirements in relation to the Monitoring Reports can be found in the ESRP. The
client will also establish in discussion with IFC appropriate project specific performance
indicators to ascertain ongoing compliance of the project with the applicable Performance
Standards and to improve its performance over time. The suggested performance indicators
can be found in the Environmental and Social Review Procedure. The client should also report
to IFC all amendments (subject to IFC’s consent) and updates to the Action Plan as part of its
Monitoring Report.
G66. The client should provide periodic updates to the affected communities at least annually
on the implementation and progress on the specific items in the Action Plan that involve ongoing
risks to or impacts on affected communities. As appropriate, where amendments and updates
to the Action Plan materially change impacts to affected communities, the client will also
disclose this to communities. In addition, information should be made available to affected
communities in response to community feedback or grievance and as a means to further involve
the affected community in the social and environmental performance of the project.
G67. Clients may wish to consider using sustainability reports to report on the financial,
environmental and social aspects of its operations, including areas of success of its
performance measures and positive project impacts that are being enhanced, as well as any
unsuccessful outcomes and the lessons learned. Reporting initiatives, guidelines, including
sector-specific guidelines, and good practices are rapidly emerging in this area. The most
notable is the Global Reporting Initiative as included in the References section. IFC can work
with clients to develop appropriate sustainability report formats upon request.
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Annex A
Content of a Social and Environmental Impact Assessment (SEIA) Report
A social and environmental impact assessment (SEIA) report focuses on the significant issues
of a project. The report's scope and level of detail should be commensurate with the project's
potential impacts and risks. The SEIA report typically includes the following items (not
necessarily in the order shown):
Policy, legal, and administrative framework. Discusses the policy, legal, and
administrative framework within which the Assessment is carried out, including
host country regulations, including obligations implementing relevant international
social and environmental treaties, agreements, and conventions, IFC Performance
Standards, as well as any additional priorities and objectives for social or
environmental performance identified by the client. Explains the environmental
requirements of any co-financiers.
Project description. Concisely describes the proposed project and its geographic,
ecological, social, health and temporal context, including any related facilities that
may be required (e.g., dedicated pipelines, access roads, power plants, water
supply, housing, and raw material and product storage facilities). Encompasses
facilities and activities by third parties that are essential for the successful
operation of the project. Normally includes maps showing the project site and the
project's area of influence.
Baseline data. Assesses the dimensions of the study area and describes relevant
physical, biological, socioeconomic, health and labor conditions, including any
changes anticipated before the project commences. Also takes into account
current and proposed development activities within the project area but not directly
connected to the project. Data should be relevant to decisions about project
location, design, operation, or mitigation measures. The section indicates the
accuracy, reliability, and sources of the data.
Social and Environmental impacts. Predicts and assesses the project's likely
positive and negative impacts, in quantitative terms to the extent possible.
Identifies mitigation measures and any residual negative impacts that cannot be
mitigated. Explores opportunities for enhancement. Identifies and estimates the
extent and quality of available data, key data gaps, and uncertainties associated
with predictions, and specifies topics that do not require further attention.
Evaluates impacts and risks from associated facilities and other third party
activities. Examines global, transboundary, and cumulative impacts as
appropriate.
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and recurrent costs; their suitability under local conditions; and their institutional,
training, and monitoring requirements. States the basis for selecting the
particular project design proposed and justifies recommended emission levels
and approaches to pollution prevention and abatement.
Appendixes:
- List of SEIA report preparers – individuals and organizations.
- References – written materials, both published and unpublished, used in
study preparation.
- Record of interagency and consultation meetings, including consultations
for obtaining the informed views of the affected communities and other
stakeholders. The record specifies any means other than consultations
(e.g., surveys) that were used to obtain the views of affected groups.
- Tables presenting the relevant data referred to or summarized in the main
text.
- Associated reports, audits, and plans (e.g., Resettlement Action Plan or
Indigenous Peoples/ Natural Resource Dependent Community plan,
community health plan).
- Action Plan that (i) describes the actions necessary to implement the
various sets of mitigation measures or corrective actions to be
undertaken, (ii) prioritizes these actions, (iii) includes the time-line for their
implementation, and (iv) describes the schedule for communicating with
affected communities when on-going disclosure or consultation is
expected.
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Annex B
Content of an Environmental Audit Report
An environmental audit report focuses on: (i) compliance of existing facilities and operations
with relevant laws and regulations, and applicable IFC Performance Standards; and (ii) the
nature and extent of significant adverse environmental impacts, including contamination of soils,
surface and ground water, and structures as a result of historical activities. The environmental
audit report typically includes the following items (not necessarily in the order shown):
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Annex C
Useful questions to assess Management Capacity and Process:
Training:
How does the client’s organization identify social and environmental training needs?
How are training needs of specific job functions analyzed?
Is training needed for contractors?
Is training developed and reviewed and modified as needed?
How is the training documented and tracked?
Monitoring:
How is social and environmental performance regularly monitored?
Have specific quantitative and/or qualitative performance indicators been
established that relate to the clients compliance requirements and management
program, and what are they?
What control processes are in place to regularly calibrate and sample environmental
measuring and monitoring equipment and systems?
What social monitoring methods are in place to track social impacts and assess
progress toward mitigation and development outcomes?
What is the process to periodically evaluate compliance with laws and regulations,
and to meet the applicable Performance Standards?
Reporting:
What social and environmental information is reported to client’s senior
management, IFC, and communities?
How is this information managed?
Is information made available to those who need it when they need it?
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Annex D
An example of Indicators and Validation Methods for Ascertaining
the Process of Free, Prior and Informed Consultation
The determination (scores) for these considerations will be made against the scaling system
used by the Environment and Social Development Department for project supervision.
3. Community Engagement
A process of consultation that is ongoing during the
project planning process (including the process of Client’s schedule and record of community
Environmental and Social Assessment), such that: engagement.
(a) affected communities have been engaged in:
(i) identifying potential impacts and risks; (ii) assessing Client’s record of discussions with recognized
the consequences of these impacts and risks for their community representatives, respected key informants,
lives; and (iii) providing input into the proposed and legitimate representatives of sub-groups (e.g.,
mitigation measures, the sharing of development women, minorities).
benefits and opportunities and implementation issues;
and that (b) new impacts and risks that have come to
light during the planning and assessment process have
also been consulted upon.
4. Information Disclosure
Client’s materials prepared for disclosure and
Timely disclosure by the client of project information by consultation.
the client to all project-affected communities about the
purpose, nature and scale of the project; the duration of Client’s record of discussions with recognized
proposed project activities; and expected risks, impacts community representatives; respected key informants;
and development benefits that directly affect them. and legitimate representatives of sub-groups.
Disclosure should be in a form that is understandable
and meaningful.
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5. Consultation
Client’s record of discussions with recognized
a) Free
community representatives, respected key informants,
Evidence from the communities adversely affected by and legitimate representatives of subgroups.
the project that the client or its representatives have not
coerced, intimidated or unduly incentivized the affected
population to be supportive of the project.
b) Prior
Consultation with affected communities must be
sufficiently early in the project planning process:(i) to
allow time for project information to be interpreted and
comments and recommendations formulated and Client’s record of discussions with recognized
discussed; (ii) for the consultation to have a meaningful community representatives, respected key informants,
influence on the broad project design options (e.g., and legitimate representatives of subgroups.
siting, location, routing, sequencing, and scheduling);
(iii) for the consultation to have a meaningful influence
on the choice and design of mitigation measures, the
sharing of development benefits and opportunities, and
project implementation.
c) Informed
Consultation with affected communities on project
operations and potential adverse impacts and risks,
based on adequate and relevant disclosure of project Client’s record of discussions with recognized
information, and using methods of communication that community representatives; respected key informants;
are inclusive (i.e., accommodating various levels of and legitimate representatives of sub-groups.
vulnerability), culturally appropriate, and adapted to the
communities’ language needs and decision-making,
such that members of these communities fully
understand how the project will affect their lives.
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The client may also use perception surveys to pose questions to affected communities and solicit their responses
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References
Several of the requirements set out in the Performance Standard are based on principles
expressed in the following international agreements and the related guidelines:
Espoo Convention – Convention on Environment Impact Assessment in a
Transboundary Context (UNECE, 1991), lays down the general obligation of states
to notify and consult each other on all major projects under consideration that are
likely to have a significant adverse environmental impact across boundaries.
http://www.unece.org/env/eia/eia.htm
In addition to the international human rights conventions referenced in GN2, the UN Convention
on the Rights of Persons with Disabilities elaborates in detail the rights of persons with
disabilities and sets out a code of implementation.
http://www.un.org/disabilities/convention/conventionfull.shtml
UN “Optional Protocol to the Convention on the Rights of Persons with Disabilities”
http://www.un.org/disabilities/convention/optprotocol.shtml
Additional international agreements are referred to at the end of other Guidance Notes.
IFC and the World Bank have published a number of resource materials:
IFC’s Environmental and Social Review Procedure (IFC, 2006), gives direction to
IFC officers in implementing the Sustainability Policy and reviewing compliance and
implementation by private sector projects.
http://ifcln1.ifc.org/ifcext/enviro.nsf/Content/ESRP
Good Practice Note: Addressing the Social Dimensions of Private Sector Projects
(IFC, 2003) – A practitioner’s guide to undertaking social impact assessment at the project
level for IFC-financed projects.
http://ifcln1.ifc.org/ifcext/enviro.nsf/Content/Publications
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World Bank’s Operational Policy 7.50 International Waterways (World Bank, 2001)
World Bank’s policy for projects that may involve the use or pollution of international
waterways.
http://lnweb18.worldbank.org/ESSD/sdvext.nsf/52ByDocName/InternationalWaterways
The following are examples of accepted international standards for formal environmental, health
and safety and social management systems:
ISO 14001 - Environmental Management Systems (International Organization of
Standardization, 2004) details the requirements for an environmental management
system, to enable an organization to develop a policy and objectives taking into
account legislative requirements and information about significant environmental
impacts. http://www.iso.org/iso/en/iso9000-14000/index.html
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DIHR Human Rights Quick Check (Danish Institute for Human Rights) - a diagnostic
self-assessment tool designed to detect human rights risks in business operations.
https://hrca.humanrightsbusiness.org/
EITI Source book (Extractives Industries Transparency Initiative – 2005) - the initiative
supports improved governance in resource-rich countries through the full publication and
verification of aggregated company payments and government revenues from oil, gas
and mining.
http://www.eitransparency.org/UserFiles/File/keydocuments/sourcebookmarch05.pdf
A Design Manual for a Barrier Free Environment (United Nations Division for Social
Policy and Development) – This Manual is a design guidebook made for the purpose
of providing architects and designers with the basic information and data necessary
for a barrier- free environment
http://www.un.org/esa/socdev/enable/designm
The U.S. Access Board – This website provides additional accessibility guidelines
and standards, technical assistance, and training downloadable publications.
http://www.access-board.gov/
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