Submission by Civil Society Organizations to the International Finance Corporation Commenting on The Social and Environmental Sustainability Policy, Performance Standards and Disclosure Policy

The document outlines systemic failures in the IFC's environmental and social due diligence, highlighting an overreliance on unverified client data and inadequate project categorization. It calls for the explicit integration of international human rights standards, including the right to free, prior and informed consent for indigenous peoples, and a strategic shift away from fossil fuel investments toward renewable energy. The authors also criticize the 'loophole' created by financial intermediaries and demand greater transparency in extractive industry contracts.

• The IFC's due diligence process is compromised by a "dangerous overreliance on client-provided information" that is not independently verified, which affects critical decisions on project impact characterization and action plans.
• Project categorization is often inaccurate, leading to insufficient risk management and reduced transparency; for example, projects in Albania and Russia were designated as category "B" despite having potential for significant impacts that warranted a category "A" designation.
• The IFC's current approach to indigenous peoples does not fully honor the right to free, prior and informed consent (FPIC) as required by the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), often substituting it with a "broad community support" standard that merely checks for the absence of major objections.
• The IFC continues to fund fossil fuel-intensive projects and large-scale livestock operations despite their contribution to greenhouse gas emissions; the authors recommend an institution-wide commitment to phase out fossil fuel investments and lower the GHG accounting threshold from 100,000 to 25,000 tonnes CO2 equivalent per year.
• Financial intermediaries (FIs) represent a significant "loophole" in the sustainability framework, as they account for 40% of IFC projects but often lack specific application guidelines, leading to a sharp decline in environmental and social performance between 2006 and 2008.
• Transparency in the extractive industry is hindered by an arbitrary threshold requiring contract disclosure only for projects accounting for 10% or more of government revenues, a requirement that has not been triggered by any of the more than 55 approved projects since 2006.
• The IFC's framework for displacement and resettlement is inadequate because it does not require clients to replace lost land with land and fails to apply the same rigorous economic feasibility tests to resettlement action plans as it does to project analyses.

APA

Center for International Environmental Law (2010). Submission by Civil Society Organizations to the International Finance Corporation Commenting on The Social and Environmental Sustainability Policy, Performance Standards and Disclosure Policy. https://www.ciel.org/wp-content/uploads/2015/04/CivilSocietySubmission_IFC_11Mar10.pdf

Chicago

Center for International Environmental Law. Submission by Civil Society Organizations to the International Finance Corporation Commenting on The Social and Environmental Sustainability Policy, Performance Standards and Disclosure Policy. 2010. https://www.ciel.org/wp-content/uploads/2015/04/CivilSocietySubmission_IFC_11Mar10.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=Submission by Civil Society Organizations to the International Finance Corporation Commenting on The Social and Environmental Sustainability Policy, Performance Standards and Disclosure Policy |date=11 March 2010 |url=https://www.ciel.org/wp-content/uploads/2015/04/CivilSocietySubmission_IFC_11Mar10.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallaw2010submission, author = {{Center for International Environmental Law}}, title = {{Submission by Civil Society Organizations to the International Finance Corporation Commenting on The Social and Environmental Sustainability Policy, Performance Standards and Disclosure Policy}}, publisher = {Center for International Environmental Law}, year = {2010}, month = mar, url = {https://www.ciel.org/wp-content/uploads/2015/04/CivilSocietySubmission_IFC_11Mar10.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }