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

A joint submission by various civil society organizations to the International Finance Corporation (IFC) criticizing its Social and Environmental Sustainability Policy, Performance Standards, and Disclosure Policy. The document argues that the IFC relies too heavily on unverified client data, fails to protect human rights—particularly those of indigenous peoples and women—and lacks transparency in its dealings with financial intermediaries and the extractive industry.

• The IFC's due diligence and oversight processes are fundamentally deficient due to an overreliance on unverified information provided by clients. This lack of independent verification affects critical decisions regarding project categorization, the creation of action plans, and the monitoring of client commitments.
• The IFC's current approach to indigenous peoples' rights does not align with the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). Specifically, the 'broad community support' (BCS) standard is criticized for failing to ensure 'free, prior and informed consent,' often being treated as a check for the absence of major objections rather than active consent.
• The IFC's framework for financial intermediaries (FIs) is described as a 'loophole' that allows high-risk projects to avoid fundamental safeguards. The document notes that environmental and social performance for FI operations declined between 2006 and 2008, and that there is a lack of public information regarding individual sub-projects within FI portfolios.
• The IFC continues to fund fossil fuel-intensive projects and large-scale livestock projects despite their contribution to greenhouse gas (GHG) emissions. The submission recommends an institution-wide commitment to phase out fossil fuel investments and suggests lowering the GHG accounting threshold from 100,000 to 25,000 tonnes of CO2 equivalent per year.
• The document identifies significant gaps in the protection of women's rights, noting that impact assessments often fail to disaggregate data by gender or address specific security, health, and land-title concerns that disproportionately affect women.
• The IFC's disclosure policy for the extractive industry is criticized for using an arbitrary threshold (10% of projected government revenues) to determine if contracts must be disclosed. The submission claims that since 2006, not a single project has triggered this requirement despite over 55 approved projects.
• The IFC's approach to displacement and resettlement under Performance Standard 5 is deemed inadequate because it only protects those physically or economically displaced, ignoring those 'constructively evicted' by pollution. It also fails to require that lost land be replaced with land of commensurate quality.

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} }