This month, Friends of the Earth US submitted feedback to the African Development Bank (AfDB) on how to strengthen the bank’s Integrated Safeguard System (ISS). Central to our review is concern for the AfDB’s extremely opaque and short public consultation process as well as the ISS’ weak protection of biodiversity and Indigenous and local community rights.

About the Review of the African Development Bank’s Integrated Safeguards System:

In 2021, the AfDB launched its review of its Integrated Safeguards System.  The ISS establishes the framework meant to protect the environment and people from potentially harmful impacts of the AfDB’s future projects. Adopted in 2014, the ISS is a critical tool to help the bank identify, anticipate, mitigate, and address the negative environmental, social, climate, and biodiversity impacts of their financing. 

Summary of FOE US’ recommendations:

1. FOE US urges the AfDB to extend its consultation process from 45 days to 90 days, which is an industry standard.
2. The bank should develop a standalone climate safeguard, so as to ensure climate issues are given due importance and attention.
3. The bank should embed alignment with the Paris Agreement and host country NDCs in the ISS.
4. The bank should establish, assess, and disclose an annual, institutional wide cap on greenhouse gas (ghg) emissions, in which all financed activities must be assessed based on ghg emissions across their entire lifecycle.
5. The bank should ensure dedicated in-house environmental or climate experts retain independence and authority to oppose activities with harmful climate impacts.
6. If the AfDB aims to take a positive approach in contributing to stopping biodiversity loss, it should remove all “no net loss” references. Instead, it should anchor its policy in a “no loss” approach which explicitly aims to halt and reverse biodiversity loss.
7. The AfDB should prohibit the use of biodiversity offsets.
8. Codify environmental and social requirements in loan and financing agreements between the bank and borrowers, with punitive clauses for clients who fail to uphold environmental and social obligations per ISS requirements
9. The AfDB should require FPIC for all Indigenous and local communities.
10. We urge the banks to more fully explore the use of exclusionary policies as a means of protecting the most sensitive areas and ecosystems left in the world. Strengthening exclusionary policies could have a large, positive impact in preempting negative environmental and social impacts in sensitive ecosystems known for their biodiversity and climate regulatory value.
11. We strongly encourage ADB to adopt the Banks and Biodiversity No Go Policy which identifies eight sensitive areas and at risk ecosystems in need of urgent protection.

FOE US’ full comments on the AfDB’s Draft Integrated Safeguards System can be found here.