The term disclosure refers to the act of disseminating information. Disclosure may occur through various means, including (but not limited to) dissemination of written/printed materials, audio-visual media, and person-to-person interactions.
Disclosure of relevant information is required by the policy frameworks of most development financial institutions.
Asian Development Bank
The Asian Development Bank's Public Communications Policy establishes the disclosure requirements for documents and information that ADB produces or requires to be produced. It mandates project documentation be posted on the web. More specific disclosure requirements are detailed in the Operations Manual (L3) on Public Communications.
With respect to social development more particularly, the ADB's Safeguard Policy Statement provides for information disclose under each of its three safeguard areas, as follows:
Environment
Policy Principle 6 - "Disclose a draft environmental assessment (including the EMP) in a timely manner, before project appraisal, in an accessible place and in a form and language(s) understandable to affected people and other stakeholders. Disclose the final environmental assessment, and its updates if any, to affected people and other stakeholders."
Policy Principle 7 - "Implement the EMP and monitor its effectiveness. Document monitoring results, including the development and implementation of corrective actions, and disclose monitoring reports."
Involuntary Resettlement
Policy Principle 9 - "Disclose a draft resettlement plan, including documentation of the consultation process in a timely manner, before project appraisal, in an accessible place and a form and language(s) understandable to affected persons and other stakeholders. Disclose the final resettlement plan and its updates to affected persons and other stakeholders."
Policy Principle 12 - "Monitor and assess resettlement outcomes, their impacts on the standards of living of displaced persons, and whether the objectives of the resettlement plan have been achieved by taking into account the baseline conditions and the results of resettlement monitoring. Disclose monitoring reports."
Indigenous Peoples
Policy Principle 7 - "Disclose a draft IPP, including documentation of the consultation process and the results of the social impact assessment in a timely manner, before project appraisal, in an accessible place and in a form and language(s) understandable to affected Indigenous Peoples communities and other stakeholders. The final IPP and its updates will also be disclosed to the affected Indigenous Peoples communities and other stakeholders."
Policy Principle 9 - "Monitor implementation of the IPP using qualified and experienced experts; adopt a participatory monitoring approach, wherever possible; and assess whether the IPP’s objective and desired outcome have been achieved, taking into account the baseline conditions and the results of IPP monitoring. Disclose monitoring reports."
International Finance Corporation
The International Finance Corporation's Access to Information Policy (AIP) establishes IFC commitments to transparency and good governance on its operations, and outlines the Corporation’s institutional disclosure obligations regarding its investment and advisory services. The AIP seeks to provide accurate and timely information regarding its investment and advisory services activities to its clients, partners and stakeholders. The policy makes available information concerning its activities that would enable its clients, partners and stakeholders (including Affected Communities), and other interested members of the public, to understand better, and to engage in informed discussion about, IFC’s business activities, the development outcomes and other impacts of its activities, and its overall contribution to development.
With respect to social development more particularly, the IFC Environmental and Social Performance Standards and Guidance Notes establish disclosure obligations for IFC clients in relation to project-level activities.
Performance Standard 1 in particular addresses effective community engagement through disclosure of project-related information and consultation with local communities on matters that directly affect them, as follows:
"Stakeholder engagement is the basis for building strong, constructive, and responsive relationships that are essential for the successful management of a project's environmental and social impacts.24 Stakeholder engagement is an ongoing process that may involve, in varying degrees, the following elements: stakeholder analysis and planning, disclosure and dissemination of information, consultation and participation, grievance mechanism, and ongoing reporting to Affected Communities. The nature, frequency, and level of effort of stakeholder engagement may vary considerably and will be commensurate with the project’s risks and adverse impacts, and the project’s phase of development."
Disclosure of relevant project information helps Affected Communities and other stakeholders understand the risks, impacts and opportunities of the project. The client will provide Affected Communities with access to relevant information26 on: (i) the purpose, nature, and scale of the project; (ii) the duration of proposed project activities; (iii) any risks to and potential impacts on such communities and relevant mitigation measures; (iv) the envisaged stakeholder engagement process; and (v) the grievance mechanism.
World Bank
The World Bank's 2016 Environmental and Social Framework establishes a set of mandatory requirements applicable to the Bank's commitments to the [Bank's activities]( "World Bank Environmental and Social Policy for Investment Project Financing"), as well as the those of its [clients]( "Environmental and Social Standards").
Although, information disclosure for client projects is mandated throughout the Environmental and Social Standards, ESS 10 is explicitly focused on requirements for disclosure of information to project-affected people. The objectives of ESS 10 are:
- To establish a systematic approach to stakeholder engagement that will help Borrowers identify stakeholders and build and maintain a constructive relationship with them, in particular project-affected parties.
- To assess the level of stakeholder interest and support for the project and to enable stakeholders’ views to be taken into account in project design and environmental and social performance.
- To promote and provide means for effective and inclusive engagement with project-affected parties throughout the project life-cycle on issues that could potentially affect them.
- To ensure that appropriate project information on environmental and social risks and impacts is disclosed to stakeholders in a timely, understandable, accessible and appropriate manner and format.
- To provide project-affected parties with accessible and inclusive means to raise issues and grievances, and allow Borrowers to respond to and manage such grievances.
Further Reading and Related Lines of Research
If you're interested to look at it (or better yet, to contribute), I am sharing some of my work on country safeguard systems in another corner of this repository.
If your interested to learn more about how social policy is articulated among development financial institutions, follow this link.
References
- Asian Development Bank. 2011. Public Communications Policy Manila: Asian Development Bank
- Asian Development Bank. 2009 Safeguard Policy Statement
- International Finance Corporation Access to Information Policy (AIP) Washington D.C.: World Bank Group
- International Finance Corporation Environmental and Social Performance Standards and Guidance Notes Washington D.C.: World Bank Group World Bank. 2016. Environmental and Social Framework Washington D.C.: World Bank Group