SUBMISSION ON PROPOSED ADAPTATION FUND ENVIRONMENTAL AND SOCIAL POLICY

The Center for International Environmental Law (CIEL) submitted recommendations to the Adaptation Fund Board to strengthen its proposed Environmental and Social Policy, emphasizing the integration of human rights due diligence and robust accountability mechanisms for implementing entities.

• CIEL recommends that the Adaptation Fund Board require systematic human rights due diligence for all projects and programmes, specifically through the use of a Human Rights Impact Assessment (HRIA). CIEL argues that standard impact assessments often fail to capture all issues that could trigger human rights violations, whereas an HRIA is anchored in a universally recognized legal framework and assesses equality, participation, and accountability.
• CIEL expresses concern over the presumption that many Fund-supported projects will entail few or no environmental and social risks. They argue that any minimal risks must be assessed, and if a determination of no impact is made, stakeholders should be notified and given an opportunity to comment or request reassessment.
• The submission urges the Board to establish clear conditions under which a project would not proceed, including the creation of an 'exclusion list' of activities the Fund will not finance and a rule that projects violating human rights should not proceed as designed.
• CIEL advocates for a two-tier grievance mechanism: first, minimum standards for mechanisms identified by implementing entities (including effectiveness, legitimacy, and accessibility), and second, the creation of an independent, robust grievance mechanism by the Fund itself to handle disputes that cannot be resolved at the implementing level.
• CIEL argues that the proposed policy lacks sufficient accountability for implementing entities. They recommend that compliance with the Environmental and Social Policy be a mandatory requirement for accreditation and re-accreditation, and that the policy explicitly define consequences for non-compliance, such as project cancellation or loss of accreditation.

APA

Center for International Environmental Law (n.d.). SUBMISSION ON PROPOSED ADAPTATION FUND ENVIRONMENTAL AND SOCIAL POLICY. https://www.ciel.org/wp-content/uploads/2014/11/AF_EnvSocPolicy_23Sep2013.pdf

Chicago

Center for International Environmental Law. SUBMISSION ON PROPOSED ADAPTATION FUND ENVIRONMENTAL AND SOCIAL POLICY. n.d. https://www.ciel.org/wp-content/uploads/2014/11/AF_EnvSocPolicy_23Sep2013.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=SUBMISSION ON PROPOSED ADAPTATION FUND ENVIRONMENTAL AND SOCIAL POLICY |url=https://www.ciel.org/wp-content/uploads/2014/11/AF_EnvSocPolicy_23Sep2013.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallawndsubmission, author = {{Center for International Environmental Law}}, title = {{SUBMISSION ON PROPOSED ADAPTATION FUND ENVIRONMENTAL AND SOCIAL POLICY}}, publisher = {Center for International Environmental Law}, url = {https://www.ciel.org/wp-content/uploads/2014/11/AF_EnvSocPolicy_23Sep2013.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }