Feburary 7, 2018
To Communications and Development Department of AIIB:
Greenovation Hub (GHUB) is a Chinese environmental NGO. We have been tracking and researching governance of new development finance since 2013, to form a responsible financing system responding to the “Paris Agreement” and “Sustainable Development Goals” (SDGs). Since 2015, we have witnessed the establishment and policy development of AIIB. We tracked and commented on the bank’s “Environmental and Social Framework” and engaged in the second round of public consultation for “Energy Strategy”. It is good to see that some our suggestions were adopted into the final version of “Energy Strategy”, and we are glad to be invited to consultations for following environmental and social policies making.
In January 2016, AIIB posted the Public Information Interim Policy (PIIP), followed on June 2017 by the Public Information Requests Processing Directive. During the publishing of these two documents, AIIB opened to comments and recommendations from related stakeholders including NGOs and CSOs. The Policy on Public Information (PPI) was drafted and the bank accordingly called for a second round of public consultation. We appreciate that AIIB paid great attention to the comments in the first round consultation and other MDBs’ benchmarks, and made revisions and responses accordingly. Our comments on the draft are as follows:
1. On Governing Principles:
We appreciated the positive adjustments that AIIB made to their principles. We noticed that AIIB decided to apply exception lists instead of disclosing certain types of information, which could widen the range of accessible information. The principle of “proactive disclosure” revealed the bank’s positive attitude and efforts on actively “promoting transparency”. The bank added “Non-discrimination and Equal Treatment” into their principles, in accordance with requirements from other MDBs such as ADB, AFDB, EBRD and WB. Based on that, we expect to see AIIB, as an “Green, Clean and Lean” rising MDB, to form its own sustainable benchmarks beyond traditional MDBs in the future.
2. On Processing Disclose Information Request:
According to article 7.2, “a written explanation” shall be provided to rejected disclosure requests. We suggest another type of written explanation could be also provided to those accepted requests in advance of disclosing related information. We also suggest AIIB to design a specific timeframe/deadline for primary response and information disclose, or lack thereof, in order to ensure the effectiveness of the request and response mechanism. For the design of the timeframe/deadline, AIIB should consider and avoid, if there is, continuous harm to the project community or people.
3. On Chief Information Disclosure Officer (CIDO) and Appeal Mechanism:
With regard to the appeal process and CIDO, we applaud AIIB’s intention to pledge the compliance on this policy by designing so. However, we would like to ask AIIB to clarify the administration arrangement of the officer and the mechanism for a clearer understanding and delivery of the policy.
4. On Exception List:
Regarding “Exception 2: Protecting the Commercial and Financial Autonomy of the Individual and Legal Entities”, we agree that information related to commercial competitiveness is critical. However, under certain circumstances, such as co-financing of development finance and private sector or through financial intermediaries, the delivery of environmental and social safeguards could be more complicated. To avoid any risks, transparency is especially required as a basic rule of environmental and social sustainability in this pattern of investments. In this case, we suggest that AIIB clarify, when environmental and social related information overlapped with the interest of the bank’s commercial partner, these documents such as environmental and social risk management, due diligence implement related to possible impacts shall not be excluded from information disclosure.
To conclude, we expect that AIIB will build on the comments and recommendations of various stakeholders and finalize the PPI at a promised date. We believe that the document will play a constructive role in AIIB’s future environmental and social risk management for sustainable investments. We expect AIIB to maintain an openness in their communications, participations and supervision of various parties. We share AIIB’s recognition of emphasizing transparency and social responsibility. We are prepared for further discussion, study, assessment and analysis in the long-term concerning AIIB’s sustainable policy making and improvment process, and we believe with these efforts, we could achieve a mutual outlook.