As part of the campaign to include child rights protections in the World Bank's safeguard policies, organisations are requested to endorse a joint letter (below and attached) to World Bank President Jim Yong Kim on the recently released first draft of the Bank's updated safeguard policies. The letter identifies a number of advances as well as concerns relating to the proposed framework from a child rights perspective.
Many organisations signed the 2012 letter, which undoubtedly contributed to some of the advances seen so far. Nonetheless, as these policies will likely become the new global standard on development policy, it is critical that protections for children are included, and to this end, your continued support is required as we enter into the second phase of the safeguards review.
The deadline for endorsements is Friday, 31 October 2014.
If you would like your organisation included in the list of endorsing organisations, please email Jolie Schwarz, Programme Associate at the Bank Information Center at [email protected].
Feel free to forward the letter to partners and other organisations.
Dr. Jim Yong Kim
The World Bank
1818 H St. NW
Washington, D.C. 20433
Dear Dr Kim,
We write today in order to comment on the World Bank’s Proposed Environmental and Social Framework, dated July 30th.
We welcome the inclusion of provisions related to child protection in the safeguard draft. We particularly appreciate the requirement in ESS 1, and the associated annex 1, that social assessments examine the risks that project impacts will disproportionately affect disadvantaged or vulnerable groups, including children. However we believe it is very important to clarify whether impact assessments will be required to look at the unique impacts of projects on children separately from other vulnerable groups or whether a general assessment of how projects impact all vulnerable groups would suffice. We must also take this opportunity to express our very serious concerns about several structural weaknesses with the draft in terms of accountability for compliance with the safeguards, the presence of a number of loopholes allowing borrowers to avoid some safeguard requirements, and a lack of detail in terms of how the safeguards will be implemented.
Because the ways in which children may be affected directly, and indirectly, by development projects vary greatly from the ways in which other vulnerable groups may be affected it is critical that impact assessments be required to look at the unique impacts of projects on children so that any potential negative impacts on children can be prevented or mitigated. Even short periods of deprivation can have long-term effects on children that can severely damage their growing minds and bodies, and can lead to further entrenching the cycle of poverty in their communities. As the World Bank itself has stated, “the economic costs of allowing child and youth deprivation can be enormous.”
In addition, ESS 4 (on Community Health and Safety) and ESS 5 (on Involuntary Resettlement) both contain references to the need to pay particular attention to “vulnerable” groups. Vulnerable is not specifically defined in either of these policies, and thus additional clarity is needed regarding whether the same definition of vulnerable groups, incorporating age related vulnerability, from ESS 1 will apply to these policies. Furthermore, as with ESS 1, it is important that these policies ensure that borrowers address the unique needs of children who may be resettled, i.e. access to quality education, as well as the unique health and safety needs of children, i.e. increased risks of sexual exploitation, rather than address all groups deemed “vulnerable” as a single entity.
There is also a need to strengthen ESS 2 (on labour). This provision should prohibit the use of child labour by contractors, and subcontractors, address the risks of child labor in the primary supply chain, and require that the minimum age for work be set in line with ILO conventions, even where these may not be reflected in national law.
Finally, we would like to commend the Bank for the inclusion of several references to the need to engage all stakeholders, regardless of age, in ESS 10 (stakeholder engagement). In particular the requirements that the borrower identify differing interests among stakeholders based on age and consider how vulnerable groups (including minors) might be differentially affected by the project in ESS10 are welcome. The fact that ESS 10 requires that the stakeholder engagement plan describe how barriers to participation, including those based upon age, will be removed is a significant step forward toward ensuring that children are included in consultations about matters that will impact their lives.
Thank you for your time and attention. We are happy to discuss this further or answer any questions you may have at your convenience.