【Article 19】AIIB must act with Transparency and Accountability

    摘要:ARTICLE 19 joins with otherinternational organisations in calling for the proposed AsianInfrastructure Investment Bank (AIIB) to engage with civil society in a moretransparent and accountable manner. The AIIB was proposed by China and issupported by 37 countries to focus on providing credit for countries in theAsia Pacific region.


Asia: Infrastructure Investment Bankmust act with Transparency and Accountability

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29 Oct 2015

ARTICLE 19 joins with otherinternational organisations in calling for the proposed AsianInfrastructure Investment Bank (AIIB) to engage with civil society in a moretransparent and accountable manner. The AIIB was proposed by China and issupported by 37 countries to focus on providing credit for countries in theAsia Pacific region.


Mr. Jin Liqun
Asian Infrastructure Investment Bank (AIIB)
9 Financial Street, Xicheng District
Beijing, China

Dear Mr. Jin Liqun:

We, the undersigned members of the Coalition for Human Rights inDevelopment and allied organizations welcome the release of the AsianInfrastructure Investment Bank (AIIB)’s draft Environmental and SocialFramework (ESF).

As a global coalition of social movements, civil societyorganizations, and community groups working to ensure that all developmentfinance institutions respect, protect, and fulfill human rights, we urgethe AIIB to adopt a robust ESF that can ensure that AIIB-financed activitiesmeet the development needs of the region, and most importantly, the needsof poor or marginalized communities. Toward this end, the ESF musteffectively ensure transparent, participative, and rights-respectingsustainable development; require strong due diligence on the part of thebank and its clients, including necessary measures to ensure compliancewith national laws, international standards, and best practices; and liveup to the commitments and obligations of the AIIB’s shareholders.

Unfortunately, we are not able to comment on the contents of thedraft ESF due to fundamental problems with the ESF consultation processwhich preclude meaningful participation by civil society, and especiallythose communities who will be most affected by AIIB’s activities.

We wish to raise the following serious concerns and critical recommendationsregarding the
consultation process:

1.Extend theconsultation timeline.Theexisting comment period is wholly inadequate for dissemination of thedraft ESF, and for civil society groups to digest and analyzeits technical contents and produce recommendations.

The consultation process should last aminimum of 4 to 6 months, following release of the draft ESF and relevantdocuments in local and regional languages.

2.Holdin-person consultations.Theuse of an on-line consultation medium, without provision for in-personmeetings, restricts access to only those civil society members who havehigh digital literacy and internet connectivity, excluding much of theregion.

The consultation process should includeface-to-face meetings at the regional, national, and local levels. Thenumber, location, and format of these meetings should be adequate toenable meaningful participation by all groups, especially those who may bemarginalized, excluded from development processes, orparticularly vulnerable to project-related harms. Consultation meetingsshould ensure accessibility for persons with disabilities, be gendersensitive and culturally appropriate, and allow for anonymouscontributions by civil society members who may fear repercussionsfor participation.

3.Utilizeactive disclosure.Theconsultation process does not have an active outreach plan, but ratherrelies on those few stakeholders who may happen to learn ofthe consultation. This biases the consultation toward English-speakingentities that closely follow development finance.

Disseminate documents in a form andformat understandable to all, including those not familiar withdevelopment finance. Active dissemination should take place through meansother than the internet. This may include distribution throughnational and local media, community gatherings, workshops, indigenouspeoples’ networks, etc.

4.Ensureaccess in regional and local languages.Because the consultationprocess establishes English as the sole means of communication for theconsultation, it excludes the majority of civil society in the region. Thefailure to translate the draft ESF into the representative languages ofthe region makes it inaccessible.

Ensure consultation meetings take placein regional languages and provide for translations of all relevantdocuments into regional and local languages.

5.Hold atleast two rounds of consultation. Holding only one round ofconsultations does not allow for a means to ensure that outcomes of theconsultation are incorporated within the revision process.

The consultation process should consistof a minimum of two rounds of consultations, wherein a record of inputsreceived during the first round is made public along with a description ofwhether and how comments were addressed. This round should then befollowed by a second round, allowing further input.

6.Provideinformation on the AIIB’s structure and operations.It is not possible to analyze theeffectiveness of the draft ESF without a clearer understanding of theAIIB’s structure, staffing, and budget for project implementation andsocial and environmental oversight.

The consultation should include not onlythe draft ESF, but additionally the transparency, disclosure andaccountability policies of the bank, including those outlining the roleand functions of the Oversight Mechanism and the guidance for the operational-levelgrievance mechanisms. Consultations should also be held on the processesthe bank will utilize for negotiation of country strategies anddevelopment priorities as well as sectoral strategies.

The AIIB could be a global leader in sustainable developmentfinance. However, to do so, it must be transparent and inclusive, andresponsive to the needs and respectful of the rights of those communitiesit aims to benefit. This requires a strong and effective Socialand Environmental Framework and an ongoing process of dialogue andpartnership with civil society.

Unfortunately in this consultation on the draft ESF, we see adeeply flawed process that appears to privilege the input ofwell-positioned English-speaking business interests at the expense of thepeople of the region. As a global coalition of social movements, civilsociety organizations and community groups, we are unable to effectivelycomment on the substance of the draft Environmental and Social Frameworkunder these conditions. We will be happy to provide input on the draft at suchtime as there is an inclusive and meaningful consultation process.

We sincerely urge you to redesign the consultation process indemonstration of an honest commitment to transparent, participative, andrights-respecting development.



Accountability Counsel, US

Alyansa Tigil Mina (Alliance Against Mining), Philippines
Centerfor Bangladesh Studies, Bangladesh

Center for International Environmental Law, US

Community Policing Partners for Justice, Security andDemocratic Reforms, Nigeria

Conseil Regional des Organisations non Governementales deDeveloppement du Kasai Oriental, Democratic Republic of Congo

EcoLur Informational NGO, Armenia

Fundación para el Desarrollo de Políticas Sustentables,Argentina

Gender Action, USA

Human Rights Center for Citizens, Mongolia

International Accountability Project, US

Otros Mundos A.C., Chiapas, México

OT Watch, Mongolia

Rivers without Boundaries, Mongolia

Sahmakum Teang Tnaut, Cambodia

Steps Without Borders NGO, Mongolia

Publish What You Pay Mongolia