Joint Submission on Responsible Exit On Consultation on the proposed IFC/MIGA Approach to Remedial Action

The document argues that the IFC's proposed Approach to Responsible Exit fails to establish remedial responsibilities for the IFC or the Multilateral Investment Guarantee Agency (MIGA), effectively allowing the institutions to exit projects without addressing harms caused by their investments. The authors contend that remedy should be a prerequisite for exit, as divestment removes the financial leverage necessary to drive corrective action. They propose four core principles: ensuring exits do not undermine ongoing Compliance Advisor Ombudsman (CAO) processes, conducting pre-divestment due diligence verified by communities, implementing meaningful consultation at least 12 months prior to divestment, and establishing protocols to prevent and manage reprisals against affected populations. The submission includes a table of projects in China, Egypt, Chile, Colombia, Nicaragua, and elsewhere where the IFC allegedly exited without providing remedy for documented harms such as forced labor, environmental damage, and human rights violations.

• The IFC's proposed Approach to Responsible Exit and Approach to Remedy do not identify specific remedial responsibilities for the IFC or MIGA, nor do they provide a comprehensive plan for delivering remedy.
• The IFC has failed to provide transparency regarding its Responsible Exit approach, refusing to release the full draft for consultation and not disclosing the results of its pilot of the Responsible Exit Principles.
• The authors argue that remedy must be a prerequisite for exit because the IFC's financial stake provides the necessary leverage to drive remedial action, which is lost upon divestment.
• The submission proposes that the IFC should not exit projects with open CAO cases or unsatisfactory E&S performance unless communities request the exit, the harm is only potential, or project implementation has not yet begun.
• A proposed framework for responsible exit includes mandatory pre-divestment assessments of E&S commitments that must be shared with and verified by affected communities.
• The authors demand that meaningful consultation with affected populations, including marginalized groups, begin at least 12 months before divestment occurs.
• The document highlights a systemic failure to prevent reprisals against community members who advocate against harmful projects, arguing that reprisal management must be a core component of the exit approach.
• The submission lists several projects where the IFC allegedly exited without notice or remedy despite severe harms, including forced labor in China (Canadian Solar, Camel Battery, Chenguang Bio, Goldwind), labor and health risks in Egypt (Titan Alex, Titan Beni Sueif), and environmental or social damage in Chile (Alto Maipo), Colombia (Ituango), and Nicaragua (Condor Gold, New Liberty).

APA

Center for International Environmental Law (n.d.). Joint Submission on Responsible Exit On Consultation on the proposed IFC/MIGA Approach to Remedial Action. https://www.ciel.org/wp-content/uploads/2023/02/Submission-for-IFC-Responsible-Exit.-April-2023.pdf

Chicago

Center for International Environmental Law. Joint Submission on Responsible Exit On Consultation on the proposed IFC/MIGA Approach to Remedial Action. n.d. https://www.ciel.org/wp-content/uploads/2023/02/Submission-for-IFC-Responsible-Exit.-April-2023.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=Joint Submission on Responsible Exit On Consultation on the proposed IFC/MIGA Approach to Remedial Action |url=https://www.ciel.org/wp-content/uploads/2023/02/Submission-for-IFC-Responsible-Exit.-April-2023.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallawndjoint, author = {{Center for International Environmental Law}}, title = {{Joint Submission on Responsible Exit On Consultation on the proposed IFC/MIGA Approach to Remedial Action}}, publisher = {Center for International Environmental Law}, url = {https://www.ciel.org/wp-content/uploads/2023/02/Submission-for-IFC-Responsible-Exit.-April-2023.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }