FAQ Index
1.The Environmental Guidelines as a whole
1.1
1.2
1.3
1.4
1.5

1.6
1.7
1.8
1.9
1.10
1.11
1.12
1.13
1.14
1.15
1.16
1.17
1.18
1.19
1.20

1.21
1.22
1.23
1.24

Q. Doesn’t JBIC disseminate to the global community how it addresses environmental issues under theEnvironmental Guidelines?
Q. If JBIC’s Environmental Guidelines differ from those of other countries, will JBIC urge such countries
to conform their guidelines to the Environmental Guidelines?
Q. What measures have been taken to disseminate the Environmental Guidelines widely among all theinterested people at home and abroad?
Q. Terms like “environmental guidelines” and “environmental and social considerations” appear frequently.
How does JBIC consider “environment” in the Environmental Guidelines?
Q. In Section 1. of Part 1 of the Environmental Guidelines, there is the statement “In cases where it isinvolved in the planning and preparatory stages of a project, JBIC will take steps to encourage borrowers
and related parties to undertake appropriate environmental and social considerations from the earliest
stage possible.” What steps will JBIC consider to take?
Q. In the Environmental Guidelines, “confirmation of environmental and social considerations” and“environmental reviews” appear frequently. In what sense were these terms used?
Q. What measures have been taken to prevent leaving out checks of all items which should be looked at ineach project?
Q. From its mandate, shouldn’t JBIC make sufficient considerations for helping Japanese companies
maintain international competitiveness?
Q. Perhaps can’t we expect JBIC to take speedy response because the Environmental Guidelines would
result in more time taken for project appraisal?
Q. In the Environmental Guidelines, the phrase “when necessary” is sometimes used. Why is it used?
Q. Won’t JBIC share common Environmental Guidelines with Nippon Export and Investment Insurance(NEXI) for the export credit portion of its operations?
Q. How did the Environmental Guidelines set forth JBIC’s role as a lender for projects?
Q. Who will conduct environmental reviews and monitoring under the Environmental Guidelines?
Q. In Section 1 of Part 2 of the Environmental Guidelines, the term “desirable” is used in several provisions.
Is this consistent with provisions in Part 1?
Q. How are human rights treated in the Environmental Guidelines?
Q. How is the scope of stakeholders stipulated in the Environmental Guidelines?
Q. What will the Environmental Guidelines do to take into account opinions of local residents affected by
the project?
Q. The Environmental Guidelines set forth that “JBIC may, if necessary, seek and make use of opinionsfrom outside experts” (Section 3. (3), Part 1). In what specific situation will JBIC turn to experts?
Q. In Section 1 (1) of Part 2 of the Environmental Guidelines it states, “a committee of experts may beformed.” Does this mean JBIC may form a committee of experts to seek the opinions of outside experts?
Q. In Section 6. (2), Part 2 of the Environmental Guidelines, it is set forth that “when project proponents
and the host governments (including local governments) other than the borrower have important roles toplay in terms of environmental and social considerations, the borrower shall endeavor to include theseparties in entering into agreements”. What situation is envisaged with “…have important roles to play”?
Where is “Japan’s national contact point on the OECD Guidelines for Multinational Enterprises” stipulated
in Section 4-(3) of Part 1 of the Environmental Guidelines?
Q. Regarding nuclear power plant projects, how are checks for ensuring safety and so on, in for example
the export of nuclear power generation-related materials and equipment, being carried out?
Q. Please provide specific points to be checked in safety and other perspectives by the Cabinet Office.
Q. In addition to preventing and controlling the adverse environmental impact of individual projects, JBIC
is also supporting projects that aim directly at environmental improvement. Does the Environmental
Guidelines cover in their scope such activities?

2.Screening and category classification
2.1
2.2
2.3

Q. With regard to category classification, what is meant by “JBIC’s share”?
Q. When projects are classified into different categories, “SDR 10 million” was used as one criterion. Whatexchange rate is applied for converting the yen to SDR?
Q. In classifying projects into different categories under the Environmental Guidelines, on what criteria doyou judge “involvement in the project of … JBIC is minor”?
1

2.4

Q. Regarding “sensitive areas” considered in category classification, Section 3. of Part 2 of theEnvironmental Guidelines stipulates in “Natural Environment” under “Sensitive Areas” “Habitats of rare
species requiring protection under domestic legislation, international treaties, etc.” Are standards set forth
by international organizations included in“international treaties, etc.”?
2.5 Q. Does JBIC automatically classify projects with “acquisition of rights and interests without additional
capital investment” as “Category C”?
2.6 Q. What is Category FI?
2.7 Q. In the case the project to be financed is specified, is it classified as Category FI if the loan is provided
by way of a financial institution?
2.8 Q. The Environmental Guidelines set forth that “JBIC conducts screening and environmental reviews ofprojects for which it intends to provide funding before making a decision.” Once a project has undergone
screening and environmental reviews, will it be subject to the same procedure when it receives additional
funding?
2.9 Q. After the screening information has been made public, is it possible for the category classification of
the project to be changed based on additional information from borrowers, stakeholders and third parties?
In that case, how will such information be disclosed?
2.10 Q. If, for example, concerns emerge for a serious environmental impact, and project classification has beenchanged from Category B to A, should the project meet requirements set under Category A in theEnvironmental Guidelines?
2.11 Q. When JBIC provides credit in cooperation with NEXI, will it result in the same project being classified ina different category?

3.Environmental reviews
3.1

3.2
3.3
3.4

3.5
3.6

3.7
3.8

3.9
3.10

3.11

3.12
3.13

Q. Do the Environmental Guidelines require compliance with international standards in addition to acts,
regulations and standards on environmental and social considerations stipulated by the government(including local governments) of the country in which a project is located?
Q. What are the World Bank ESSs and the IFC Performance Standards, of which JBIC ascertains whether
a project meets the relevant aspects?
Q. What kinds of international standards and good practices could be used as a reference for environmental
and social considerations in the Environmental Guidelines?
Q. When acts, regulations and standards on social and environmental considerations established by thegovernment (including local governments) of the country in which the project is located are lax comparedwith their international counterparts, how does JBIC respond?
Q. How are the results of environmental reviews being used in the decision-making of JBIC and in thefunding agreements?
Q. The provisory clause of Part 1, Section 6 (1) of the Environmental Guidelines states that “in exceptional
cases where, given the nature of the project, documents necessary for environmental reviews are notavailable at the time that a decision on the funding must be made, JBIC may make a decision on the fundingon the condition that it will undertake the environmental reviews after decision making.” In what case andin what procedures is this clause applied?
Q. What are review procedures for Category FI?
Q. The Environmental Guidelines set forth, “consultation with stakeholders, such as local residents, musttake place after sufficient information has been disclosed. Records, etc. of such consultations must be
prepared.” (Section 2, Part 2) Will JBIC confirm whether consultations have taken place?
Q. What issues will be considered with regard to gender, children’s rights, HIV/AIDS and othercommunicative diseases by JBIC under the Environmental Guidelines?
Q. In Part 2, Section 1. (3), “community health, safety, and security” is listed as one issue of the scope of
the project whose impact should be considered. What do you confirm, in particular, regarding the use of
security personnel in this respect?
Q. In Section 1. (3) of Part 2 of the Environmental Guidelines, “While air could include greenhouse gases(GHG), specific requirements for environmental and social considerations on this issue are to be madebased on the Common Approaches”. What provisions exist in the Common Approaches? Let us also know
about the state of standards of international financial institutions used as benchmarks.
Q. There is a phrase “associated facilities” in Part 2, Section 1. (3) of the Environmental Guidelines, what
facilities does it refer to?
Q. In Part 2, Section 1 (6) of the Environmental Guidelines of JBIC, there is a clause which states “criticalnatural habitats including critical forest areas” and “natural habitats including natural forests.” Please
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3.14
3.15

3.16

3.17

3.18

3.19

identify what areas they are. Also, please provide specific examples of “significant conversion ordegradation.”
Q. When the project involves involuntary resettlement, how does JBIC confirm the consent of the local
inhabitants?
Q. In Section 1. (7) of Part 2 of the Environmental Guidelines, there is a clause which states “It is desirable
that the resettlement action plan includes elements required in the standard of international financial
institution which JBIC benchmarks.” Specifically, are the elements required by which standard?
Q. In Section 1. (8) of Part 2 of the Environmental Guidelines, there is a clause which states “When aproject may have adverse impact on indigenous peoples’, various rights in relation to land and resources,
such rights must be respected in accordance with the spirit of the relevant international declarations andtreaties, and free, prior, and informed consents must be obtained.” What are the international declarations
and treaties relating to indigenous peoples?
Q. Section 1. (8) of Part 2 of the Environmental Guidelines set forth that when a project may have any
adverse impact on the rights of indigenous peoples, “free, prior, and informed consents must be obtained.”
What kinds of procedures and consent are required?
Q. In Section 1. (8) of Part 2 of the Environmental Guidelines, there is a clause which states “It is desirable
that the indigenous peoples plan include the elements required in the standard of international financial
institutions which JBIC benchmarks.” Specifically, what standards are required for the elements?
Q. In the case that a project has a significant impact on the residents living around the project site, should
JBIC listen to the voices of potentially affected residents in a field study conducted at the project site asa part of its environmental reviews?

4.Monitoring
4.1
4.2
4.3
4.4
4.5
4.6
4.7

Q. What is the purpose of monitoring?
Q. Why do the Environmental Guidelines not stipulate in advance items requiring monitoring and themonitoring period?
Q. Are studies of proposed project sites JBIC conducts for monitoring different from field studies
implemented already?
Q. It is important to conduct monitoring appropriately. What specific measures is JBIC taking to strengthen
the environmental monitoring system?
Q. How long is the monitoring period? Even when it is clear that project operation is appropriate, isn’t it
inefficient to continue monitoring that project?
Q. Doesn’t JBIC conduct monitoring for sub-projects of Category FI projects?
Q. Won’t JBIC give encouragement once a project is classified as “Category C”?

5.Information disclosure
5.1

Q. What is the concept upon which the provisions pertaining to information disclosure in the Environmental
Guidelines is based?
5.2 Q. Environmental Guidelines state “JBIC endeavors to achieve further disclosure of information byencouraging project proponents”. Especially, what information do you endeavor to disclose?
5.3 Q. Are information disclosure provisions of the Environmental Guidelines in line with the Common
Approaches?
5.4 Q. Where does information disclosure under the Environmental Guidelines stand in relation to information
disclosure under the “Act Concerning Disclosure of Information Possessed by Independent Administrative
Institutions” (the “Information Disclosure Act”)?
5.5 Q. How did JBIC disseminate information on the preparations and content of the Environmental Guidelines
to the domestic public?
5.6 Q. Based on the Environmental Guidelines, what kind of information regarding individual projects is madeavailable to the public on the JBIC website?
5.7 Q. Will the name of the project company be disclosed as part of information disclosure?
5.8 Q. Isn’t it inappropriate to exempt some information from disclosure on the ground of business
confidentiality?
5.9 Q. What is the timing of information disclosure on the screening information?
5.10 Q. Given the provision, “It endeavors to make such disclosure well in advance of the decision-making”(Environmental Guidelines Part 1 Section 5-(2)2)) at what timing will decisions be made?
5.11 Q. How long are disclosure periods for the results of screening and environmental reviews for projects?
5.12 Q. Will ESIA reports and permit certificates on Category A projects be disclosed in Japan as well?
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5.13 Q. In Section 5-(2) of Part 1 of the Environmental Guidelines, there is a clause which states, “documents
other than ESIA reports and permit certificates … obtained from the borrowers and related parties forconfirming environmental and social considerations”. What kinds of documents does this refer to?
5.14 Q. In Section 5. (2) 2) of Part 1 of the Environmental Guidelines, there is a clause which states “The statusof acquirement of documents other than ESIA reports and permit certificates, and such documents
obtained from the borrowers and related parties for confirming environment and social considerations ifsuch documents are publicly available in the host country.” Even if the borrower and related parties
consent, won’t JBIC make such information and documents available, for any status of their publicavailability in the host country?
5.15 Q. In many cases, the local residents affected by the project have no access to the JBIC website. How
can these people obtain information on the project?
5.16 Q. Can’t the findings of environmental reviews be disclosed at an early date?
5.17 Q. Why doesn’t JBIC make available to the public ex-ante evaluation reports for the projects?
5.18 Q. Will the details of the funding agreement be made public after its signing?
5.19 Q. Is any information disclosure stipulated in the Environmental Guidelines, relating to monitoring?

6.ESIA reports and permit certificates and other essential information
6.1
6.2

6.3
6.4
6.5
6.6
6.7

Q. From what sources is information on projects concerning the environment collected?
Q. In Section 2 of Part 2 of the Environmental Guidelines, there is a clause which states “It is desirable
that ESIA reports cover the items stipulated in the Common Approaches.” Given that, which part of theCommon Approaches stipulates those items?
Q. JBIC’s Environmental Guidelines stipulate that ESIA reports and permit certificates should be released
to the public. Are there any countries where this is legally forbidden?
Q. Could demanding the disclosure of an ESIA report or a permit certificate by ignoring the domestic
institutional setup of host country constitute interference with the domestic affairs of that country?
Q. Is the information sought in the Environmental Guidelines from borrowers relating to the environment
actually available?
Q. Suppose a third party provides to JBIC, information of little credibility whose validity it cannot establish
in an effort to thwart the project. What kind of information will JBIC deal with and how?
Q. The Section 4. (4) of Part 1 of the Environmental Guidelines set forth, “The information necessary formonitoring needs to be supplied by the borrower and related parties by appropriate means.” In the casethat the borrowers do not participate in project management, they do not have access to information,either. Even then, do the borrowers still have an obligation to supply information?

7.Application and Review of the Environmental Guideline
7.1
7.2
7.3

Q. What is the process through which the Environmental Guidelines that is in effect from July 2022 wererevised?
Q. Given that the revised Environmental Guidelines came into full force in July 2022, are they applied tothe projects for which funding requests are made after that time?
Q. Will the Environmental Guidelines be periodically revised in the future?

8.Other
8.1
8.2

Q. Does an English version of the Environmental Guidelines exist?
Q. What is FAQ?

4

1.The Environmental Guidelines as a whole
1.1

Q. Doesn’t JBIC disseminate to the global community how it addresses environmental issues under theEnvironmental Guidelines?
A. JBIC is disseminating the concept of JBIC Guidelines for Confirmation of Environmental and Social
Considerations (the “Environmental Guidelines”), which have been compiled by taking into accountcomments from the public, through briefings and information dissemination in international conferences of
the Organization for Economic Cooperation and Development (OECD) as well as in consultation meetings
with the governments of developing countries.

1.2

Q. If JBIC’s Environmental Guidelines differ from those of other countries, will JBIC urge such countries
to conform their guidelines to the Environmental Guidelines?
A. In the process of revising Recommendation of the Council on Common Approaches for OfficiallySupported Export Credits and Environmental and Social Due Diligence (the “Common Approaches”), JBIC
contributed to fruitful discussions by presenting contents of our own Environmental Guidelines and by
making constructive revision proposals in cooperation with the Japanese government. JBIC will continue
to contribute to the evolution of the Common Approaches in days to come.

1.3

Q. What measures have been taken to disseminate the Environmental Guidelines widely among all theinterested people at home and abroad?
A. JBIC is making active efforts to disseminate information relating to the Environmental Guidelines on the
JBIC website and in its public information magazines. JBIC also explains to the industry how we implement
the Environmental Guidelines, and exchange opinions with entities such as government ministries andagencies related to the environment in developing countries.
JBIC intends to continue its efforts to further improve the internal system supporting the Environmental
Guidelines and to deepen their understanding among various concerned parties.

1.4

Q. Terms like “environmental guidelines” and “environmental and social considerations” appear frequently.
How does JBIC consider “environment” in the Environmental Guidelines?
A. The Environmental Guidelines classify issues of environmental and social considerations into three
categories: those involving pollution prevention/abatement, the natural environment and the social
environment. The social environment is also one of the important components of confirming environmental
and social considerations. Based on this stance, JBIC also defines “the environment” as the term that
“refer not only to the natural environment, but also to the social environment” in the preface.
At JBIC, the term “Environmental Guidelines” is considered easier to get used to than “Environmental andSocial Guidelines” as an abbreviation. Meanwhile, in the JBIC Environmental Guidelines, confirming
considerations for resettlement, and socially vulnerable groups like indigenous peoples is recognized to bevery important. To make this point more explicit, JBIC has adopted the expression “Environmental andSocial Considerations” rather than “Environmental Considerations” as the formal title.

1.5

Q. In Section 1. of Part 1 of the Environmental Guidelines, there is the statement “In cases where it isinvolved in the planning and preparatory stages of a project, JBIC will take steps to encourage borrowers
and related parties to undertake appropriate environmental and social considerations from the earliest
stage possible.” What steps will JBIC consider to take?
A. When JBIC makes equity participation in a company that conducts feasibility studies in the planning andpreparatory stages of a project, JBIC considers that it can work on that company to include theenvironmental aspect in the scope of that study as a shareholder. In addition, in the case that such company
5

conducts the compiling of a master plan, JBIC will consider to make a proposal that includes the conceptof strategic environmental assessment as well.

1.6

Q. In the Environmental Guidelines, “confirmation of environmental and social considerations” and“environmental reviews” appear frequently. In what sense were these terms used?
A. JBIC confirms the appropriateness of environmental and social considerations in 3 stages: screening,
environmental reviews and monitoring. “Environmental reviews” are a component of the process ofconfirming environmental and social considerations. The Environmental Guidelines give the following
stipulations.
For confirmation of environmental and social considerations, JBIC undertakes:
1) classification of the project into one of the categories listed in Section 4. (2) of Part 1 (hereinafterreferred to as “screening”);
2) reviews of environmental and social considerations when making a decision on funding, to confirm thatthe requirements are duly satisfied (hereinafter referred to as “environmental reviews”); and3) monitoring and follow-up after the decision on funding has been made (hereinafter referred to as“monitoring”).

1.7

Q. What measures have been taken to prevent leaving out checks of all items which should be looked at ineach project?
A. At JBIC, sufficient use is made of the screening form and environmental checklists to ensure that all
check items are covered, while further measures are used in combination to compliment this. For example,
for projects classified in Category A, JBIC recognizes it as effective to confirm public consultation
procedures and the status of information disclosure in the host country in order to avoid missing out check
items. The Environmental Guidelines stipulates in Section 3-(3) of Part 1 that “For Category A projects(see Section 4. (2) of Part 1), JBIC checks the extent of stakeholder participation and information
disclosure being undertaken for the project,” and “JBIC may conduct surveys of proposed project sites by
dispatching environmental experts to confirm environmental and social considerations if necessary”, andJBIC is putting much effort into appropriate application of these provisions.

1.8

Q. From its mandate, shouldn’t JBIC make sufficient considerations for helping Japanese companies
maintain international competitiveness?
A. Since it is recognized that striking a balance between environmental conservation and achieving
sustainable projects is an important challenge on a global level, in drawing up the Environmental Guidelines,
JBIC considered consistency between its mission of financial support for overseas business activities ofJapanese companies and environmental and social considerations to be of extreme importance and thus
gave it top priority.
In the future, JBIC will continue to confirm the appropriate environmental and social considerations. While
being bound by this requirement, the Environmental Guidelines intends to give sufficient attention tomaintaining and strengthening the international competitiveness of Japanese companies by making
considerations for business confidentiality.

1.9

Q. Perhaps can’t we expect JBIC to take speedy response because the Environmental Guidelines would
result in more time taken for project appraisal?
A. Whereas it is necessary to confirm to the full extent whether environmental and social considerations
are appropriate depending on sector and the nature of an individual project, JBIC should not hinder theforward momentum of the project by delays in its appraisal procedures. In particular, this point should be
kept in mind in the case of supporting projects undertaken by private enterprises.
6For this reason, to seek greater speed while ensuring sufficient confirmation of environmental and social
considerations, JBIC considers the following measures:・ Conducting “screening” to identify projects with the potential to have significant adverse impacts on
the environment. Such projects are subject to more elaborate confirmation of environmental and social
considerations.
・ Making good use of a screening form, which compiled a set of questions for the borrowers and relatedparties, and checklists, which provide a list of items to be confirmed for each sector.
・ Sharing information and exchanging views with cofinancing other financial institutions and ECAs.
・ Making use of outside experts on the relevant specific sector in accordance with the nature andcontent of projects.

1.10 Q. In the Environmental Guidelines, the phrase “when necessary” is sometimes used. Why is it used?
A. The Environmental Guidelines apply to the full diversity of projects. As such there is a range of different
elements, including financial instruments (export loans, import loans, overseas investment loans, untied
loans, equity participation, etc.); the nature of projects (projects undertaken by private enterprises or by
the government, projects on a project finance scheme, funding for the project which internationalorganizations promote); and the timing incorporated in the projects. Thus, it is difficult to apply uniform
standards to all the projects.
If the cases were carefully classified, there is a danger that the details would become overly complicated,
and for some projects, flexible handling on a case-by-case basis is most appropriate. In consideration ofthese points, this term is used to make the Environmental Guidelines easier to read and more efficient.

1.11 Q. Won’t JBIC share common Environmental Guidelines with Nippon Export and Investment Insurance(NEXI) for the export credit portion of its operations?
A. Firstly, JBIC makes use of a variety of financial instruments to support projects implemented indeveloping countries, including export credits, overseas investment loans, import loans, untied loans,guarantees and equity participations. When doing so, as a policy-based financing institution, JBIC should
basically require the same level of environmental and social considerations for projects it finances,according to the financial instruments it employs.
Secondly, credit by NEXI is in the form of insurance and as such the shape of its involvement in the project
and the procedures differ from those of JBIC. This results in difficulty in making the Environmental
Guidelines of both organizations completely the same. In actuality though, there are no large differences
between the contents of the two guidelines.
As the Common Approaches encourage information sharing among ECAs, JBIC is working with NEXI toconsider convenience for export credit users by:
・ Standardizing a screening form, which includes questions for the borrower; and checklists, which list
up items to be confirmed for each sector.
・ Sharing information pertaining to environmental and social considerations;・ Sending out a field study mission at the same time whenever possible; and・ Exchanging views on findings of respective environmental reviews.

1.12 Q. How did the Environmental Guidelines set forth JBIC’s role as a lender for projects?
A. As a Japanese policy-based financing institution, JBIC will confirm the appropriateness of environmental
and social considerations of all JBIC-funded projects, in accordance with the Environmental Guidelines. At

7the same time, JBIC extends positive support to projects contributing to environmental conservation,
including global environmental conservation, and environmental improvement.
In the Environmental Guidelines, procedures and evaluation criteria are set forth for JBIC’s confirmationof environmental and social considerations, to ensure that they are carried out in the appropriate manner
in JBIC-funded projects. Also clearly stipulated are the details(Note) of requirements for environmental andsocial considerations for project proponents who implement projects. For this reason, if considerations are
deemed inadequate, JBIC will ask for action to address this deficiency, and if appropriate environmental
and social considerations are still not assured, JBIC may, as a policy-based financing institution, decide
not to provide funding.
After the agreement of funding is signed, monitoring takes place. If JBIC determines that there is a needfor improvement in environmental and social considerations, it may ask the project proponent for
appropriate action. Further, if the response of the project proponent is still unsatisfactory, JBIC may
consider the suspension of disbursement. In this way, as a policy-based financing institution, JBIC intends
to continue to actively address the issue of appropriate environmental and social considerations in projects.
(Note) If the project proponent is to undertake the project in a sustainable manner, the internationalcommon recognition is that it should be equally responsible for the environmental and social considerationsin the applicable project. The details of environmental and social considerations JBIC wants the project
proponent to make, and the procedure are described in Section 1-2 of Part 2 of the Environmental
Guidelines.

1.13 Q. Who will conduct environmental reviews and monitoring under the Environmental Guidelines?
A. In the Environmental Guidelines, environmental reviews and monitoring must be conducted first by the
project proponent who has close knowledge of and handles the project. Meanwhile, to ensure its
transparency and objectivity, the following obligations of the project proponent were set forth in theEnvironmental Guidelines:(1) “When assessment procedures already exist in the host countries, and the projects are subject to suchprocedures, borrowers and related parties must officially complete those procedures and obtain theapproval of the government of the host country.” (Part 2, Section 2)(2) “ESIA reports are required to be made available in the country and to the local residents where theproject is to be implemented.” (Part 2, Section 2)(3) “Sufficient consultations with stakeholders, such as local residents, must be conducted … The outcomeof such consultations must be incorporated into the content of the project plan.” (Part 2, Section 1(5))(4) “It is desirable that project proponents make the results of the monitoring process available to projectstakeholders.” (Part 2, Section 1(9))

1.14 Q. In Section 1 of Part 2 of the Environmental Guidelines, the term “desirable” is used in several provisions.
Is this consistent with provisions in Part 1?
A. The Environmental Guidelines consists of Part 1, which clarifies JBIC’s basic policies and procedures,
and Part 2, which sets forth more specific issues on environmental and social considerations for the
projects funded by JBIC.
Among the provisions for the specific issues are those that are recommended (“desirable”) and those thatare mandatory (“must,” “have to” or “should”). This term has been used in order to distinguish between
the two.

1.15 Q. How are human rights treated in the Environmental Guidelines?
A. Preface of the Environmental Guidelines state that “Environmental and social considerations refer not
only to the natural environment, but also to the social environment (hereinafter collectively referred to as8

“environment”), including human rights”. Also, with respect to human rights, as Section 1. (3) “Scope of
Impact to be Examined” of Part 2 treat “social concerns including respect for human rights” as one of theenvironmental impacts which should be investigated and examined, JBIC thus considers human rights as aconstituting factor of this social environment.
On the other hand, the concept of human rights is broad. There is a full spectrum of human rights issues
ranging from those at the national level to the project level. JBIC’s Environmental Guidelines aim at
weighing the environmental and social impacts caused by individual projects JBIC is involved in and willaddress specific issues at the individual project level. JBIC will be able to address human rights issues tothe extent that there are clear standards.
Based on this concept, the issues to be examined have been clarified in the Environmental Guidelines. In
concrete terms, the Environmental Guidelines state involuntary resettlement, the rights of indigenous
peoples, and vulnerable social groups, including women and children as the item which should be confirmed
at the project level.
Human rights issues that can be addressed most effectively at the state level are not covered by theEnvironmental Guidelines. It is desirable that human rights issues that can be addressed most effectively
at the national level are addressed at the national policy level through diplomacy, and not covered by theEnvironmental Guidelines.

1.16 Q. How is the scope of stakeholders stipulated in the Environmental Guidelines?
A. Stakeholders are defined in Section 1 of Part 1 as “stakeholders in the project concerned, including
local residents and local NGOs affected by the project.”Those living in the area where there is a risk of being adversely affected by the project may become
stakeholders, and they are not limited to those living at the project site. Such areas may extend intoneighboring countries, and JBIC believes it should not exclude from stakeholders the people living in thevicinity of the project site only because they reside in different countries.
On the other hand, environmental assessment is conducted based on the systems in the project-dwellingcountry. And since consultations with the stakeholders will take place under this procedural framework,
the question of how to hold consultations will be handled on a case-by-case basis by taking into accountindividual projects and conditions in the surrounding areas.

1.17 Q. What will the Environmental Guidelines do to take into account opinions of local residents affected by
the project?
A. JBIC considers it necessary to take into account opinions of the people likely to be affected by the
project, including such socially vulnerable groups as women, children, the aged, the poor and ethnic
minorities.
The Environmental Guidelines stated in Section 1(5) of Part 2, “sufficient consultations with stakeholders,such as local residents, must be conducted … The outcome of such consultations must be incorporated
into the content of the project plan. The consultations with affected people should be a two-way processthat is free of external manipulation, interference, coercion, or intimidation.” “Appropriate considerationmust be given to vulnerable social groups, such as women, children, the elderly, the poor, and ethnic
minorities … who may have little access to the decision-making process within society.” and “It is
recommended that project proponents establish a point of contact for complaints in order to receive
complaints from stakeholders such as local residents at an early stage and to promote their resolution.” Incases of “Involuntary Resettlement” and “Indigenous Peoples” too, it stipulates consultation with thoseaffected peoples.
Furthermore, JBIC considers it important to collect information broadly in confirming environmental andsocial considerations. Section 5-(1) of Part 1 stated, “JBIC makes important information on environmental
reviews … publicly available” and “JBIC welcomes information provided by concerned organizations andstakeholders.”
91.18 Q. The Environmental Guidelines set forth that “JBIC may, if necessary, seek and make use of opinionsfrom outside experts” (Section 3. (3), Part 1). In what specific situation will JBIC turn to experts?
A. For example, in the process of confirming the appropriateness of environmental and social considerationsin individual projects, when JBIC deems it necessary to seek advice based on specialized and technicalknowledge, it will make use of outside experts. In this case, experts JBIC will turn to are not necessarily
Japanese. They may well be local experts.

1.19 Q. In Section 1 (1) of Part 2 of the Environmental Guidelines it states, “a committee of experts may beformed.” Does this mean JBIC may form a committee of experts to seek the opinions of outside experts?
A. JBIC believes it is important to seek opinions of outside experts regarding projects that are likely tohave a particularly large adverse impact or are highly contentious. JBIC has made positive use of opinionsof outside experts such as consultants for projects that are considered to have a significant adverse
impact.
On the other hand, it is JBIC’s position that the process of seeking experts’ opinions should take placeas part of environmental and social considerations made by project proponents. Thus the provision setting
forth the formation of a committee of outside experts was one of the items listed in Section 1, Part 2 of
the Environmental Guidelines for environmental and social considerations in applicable projects.
Environmental and Social Standard (ESS) 1 of the World Bank, also makes it the responsibility on the partof the borrower: “For projects that are High Risk or contentious, or that involve serious multidimensional
environmental or social risks or impacts, the Borrower may be required to engage internationally recognizedindependent experts. Such experts may, depending on the project, form part of an advisory panel or beotherwise employed by the Borrower, and will provide independent advice and oversight to the project.”1.20 Q. In Section 6. (2), Part 2 of the Environmental Guidelines, it is set forth that “when project proponents
and the host governments (including local governments) other than the borrower have important roles toplay in terms of environmental and social considerations, the borrower shall endeavor to include theseparties in entering into agreements”. What situation is envisaged with “…have important roles to play”?
A. In some projects, the government plays an important role in addition to the borrower and the project
proponent. For instance, there are cases in which involuntary resettlement occurs as a result of the project,
and the government is expected to play a special role in providing compensation.
In such cases, it should be ensured, where necessary, that the government plays its role through anagreement and other arrangements between the project proponent and the government.

1.21 Where is “Japan’s national contact point on the OECD Guidelines for Multinational Enterprises” stipulated
in Section 4-(3) of Part 1 of the Environmental Guidelines?
A. Japanese national contact points are as follows:
・ OECD Division of Economic Affairs Bureau, Ministry of Foreign Affairs
・ International Affairs Division of Minister’s Secretariat, Ministry of Health, Labour and Welfare
・ Trade and Investment Facilitation Division of Trade and Economic Cooperation Bureau, Ministry of
Economy, Trade and Industry

1.22 Q. Regarding nuclear power plant projects, how are checks for ensuring safety and so on, in for example
the export of nuclear power generation-related materials and equipment, being carried out?
10

A. When considering financing for projects in which equipment and materials related to nuclear power
generation are exported or handled otherwise, JBIC requests that the Cabinet Office perform a check of
the considerations pertaining to safety assurance and so on, in the corresponding project.
The Cabinet Office checks that the project is carried out based on appropriate safety considerations fromthe perspective of safety, radioactive waste and nuclear accident measures so that the project will notlead to a nuclear accident or inappropriate disposal of nuclear waste in the host country or region.

1.23 Q. Please provide specific points to be checked in safety and other perspectives by the Cabinet Office.
A. The Cabinet Office checks whether items (1), (2), or (3) shown below has been implemented properly
for each project.
(1) Observance of international agreements for security in the host country or region and organizeddomestic systems(2) Conclusion of agreements on quality assurance by suppliers and preparedness for provision of
security-related services(3) Acceptance of key reviews by the International Atomic Energy Agency (IAEA) and status ofacquirement of relevant permit certificates (in the case of nuclear power plant installation)

1.24 Q. In addition to preventing and controlling the adverse environmental impact of individual projects, JBIC
is also supporting projects that aim directly at environmental improvement. Does the Environmental
Guidelines cover in their scope such activities?
A. The Environmental Guidelines refers to projects that aim directly at environmental improvement. In its
preface, there is an explicit statement: “JBIC will provide active support based on policies of the Japanese
government for projects that promote environmental conservation, and for projects that contribute to thepreservation of the global environment, such as reduction of greenhouse gas emissions.”
Also, although not explicitly stated in the Environmental Guidelines, when JBIC approves financing projects,
preferential terms and conditions are sometimes applied, in projects which satisfy certain requirements andwill contribute to global environmental preservation, such as renewable energy and energy conservation
projects, projects for environmental measures, and recycling projects, and proactive support is given forsuch projects in this way.

11

2.Screening and category classification
2.1

Q. With regard to category classification, what is meant by “JBIC’s share”?
A. JBIC’s share means the amount financed by JBIC, excluding the portion co-financed by other financial
institutions. The term “JBIC’s share” has come to be used because JBIC applies a variety of financial
tools.

2.2

Q. When projects are classified into different categories, “SDR 10 million” was used as one criterion. Whatexchange rate is applied for converting the yen to SDR?
A. SDR 10 million is approximately 1.79 billion yen (as of June 10, 2022). Please see the IMF website fordetails on SDR exchange rates.
IMF website on SDR (Special Drawing Rights) exchange rates

2.3

Q. In classifying projects into different categories under the Environmental Guidelines, on what criteria doyou judge “involvement in the project of … JBIC is minor”?
A. It is defined as such a low level of commitment that JBIC can hardly have a say in how the project
proponent should make environmental considerations for the project. For example, if JBIC’s financing shareis equal or less than 5% of the total project cost, JBIC may regard its involvement in such a project as“minor.”

2.4

Q. Regarding “sensitive areas” considered in category classification, Section 3. of Part 2 of theEnvironmental Guidelines stipulates in “Natural Environment” under “Sensitive Areas” “Habitats of rare
species requiring protection under domestic legislation, international treaties, etc.” Are standards set forth
by international organizations included in“international treaties, etc.”?
A. “International treaties, etc.” stipulated under “Sensitive Areas” do not necessarily include all thestandards set forth by international organizations. However, in category classification, JBIC considers
standards referred to by the World Bank and IFC such as the Red List of Threatened Species of IUCN.

2.5

Q. Does JBIC automatically classify projects with “acquisition of rights and interests without additional
capital investment” as “Category C”?
A. No. Through the screening form and a hearing with the borrower, JBIC confirms that the projects inquestion are not “projects with sensitive characteristics” nor “projects located in sensitive areas”, andthat there is no strong claim from local residents to executing projects (a “negative check”). After this has
been confirmed, JBIC confirms, as necessary, the borrower’s and related parties’ policy on environmental
and social considerations and their capacity to undertake such considerations, and if JBIC judges that the
projects with “acquisition of rights and interests without additional capital investment” have the nature ofcausing no additional adverse environmental impact (or minimal adverse environmental impact), they will beclassified as “Category C”. Similarly, in the case of other projects than those with “acquisition of rights
and interests without additional capital investment”, JBIC performs a negative check on such matters as
the business characteristics of the borrower and related parties and confirms, as necessary, such mattersas the borrower’s and related parties’ policy on environmental and social considerations, and if JBIC
judges that the projects are likely to have minimal or no adverse environmental impact, they will be classified
as “Category C”.
Furthermore, if in general, an existing project falls under a sensitive sector (as illustrated in Section 3-(1)of Part 2 of the Environmental Guidelines), JBIC confirms the reputation regarding its environmental and12social considerations with the utmost attention by checking into the contents of local media reports andgathering relevant information through our representative offices, to the extent possible, and thencategorizes it.
The reason why a project with “acquisition of rights and interests without additional capital investment” isexemplified as “Category C” is not only because it will generally cause no additional adverse environmental
impact (or minimal adverse environmental impact), but also because JBIC is putting across the message
that it is also prepared to handle such fast-track projects, to the best of its ability since JBIC is often
requested to make a decision on financing the project faster than other projects by both the project owner
who needs the funding and the fund provider who seeks the acquisition of rights and interests such as
Japanese companies (furthermore, a case of competition over the project with other companies can bealso envisioned).

2.6

Q. What is Category FI?
A. A proposed project is classified as Category FI if subprojects to be funded are not specified at the timeof the signing of a funding agreement, and therefore it is a category for which JBIC cannot confirm
environmental and social considerations for prior to the funding agreement.

2.7

Q. In the case the project to be financed is specified, is it classified as Category FI if the loan is provided
by way of a financial institution?
A. Category FI is only applied to cases where projects to be funded are not specified prior to the signingof a funding agreement. If the project is specified prior to the signing of a funding agreement, the project
is not classified as Category FI even if the funding is provided by way of a financial intermediary. The
project will then be classified as Category A, B, or C.

2.8

Q. The Environmental Guidelines set forth that “JBIC conducts screening and environmental reviews ofprojects for which it intends to provide funding before making a decision.” Once a project has undergone
screening and environmental reviews, will it be subject to the same procedure when it receives additional
funding?
A. We do not think it is necessary for a project that has undergone screening and environmental reviews
to repeat them, if the impacts the project has on the environment and the basis for its category ofclassification do not differ significantly from those foreseen by the first screening and review.

2.9

Q. After the screening information has been made public, is it possible for the category classification of
the project to be changed based on additional information from borrowers, stakeholders and third parties?
In that case, how will such information be disclosed?
A. The category designated to a project and made available to the public before the signing of the funding
agreement is a tentative designation and should not be considered definitive. Therefore, as new information
is obtained, it is possible to change category designation after making public the screening information. On
such occasions, JBIC aims to promptly release the change and its reasons on its website.

2.10 Q. If, for example, concerns emerge for a serious environmental impact, and project classification has beenchanged from Category B to A, should the project meet requirements set under Category A in theEnvironmental Guidelines?
A. In this kind of situation, JBIC will encourage the borrower to meet requirements set under the newly
designated category. However, when the project is being implemented, JBIC considers it is more importantto take measures to resolve the problem arisen rather than meeting the requirements under the new13

category. JBIC will engage the borrower to this end, if deemed necessary after consideration of thesituation.

2.11 Q. When JBIC provides credit in cooperation with NEXI, will it result in the same project being classified ina different category?
A. That is theoretically possible. In reality though, JBIC and NEXI possess Environmental Guidelines which
are broadly the same, and we cooperate as much as possible in designating a category for the project.
Working in this way is to the convenience of the borrowers.

14

3.Environmental reviews
3.1

Q. Do the Environmental Guidelines require compliance with international standards in addition to acts,
regulations and standards on environmental and social considerations stipulated by the government(including local governments) of the country in which a project is located?
A. JBIC examines compliance with environmental laws and standards of the host nation and local
governments concerned in confirming environmental and social considerations. JBIC also ascertains
whether a project meets the following standards.
・ World Bank ESSs or IFC Performance Standards; or・ IFC Performance Standards in the cases of (i) limited recourse or non-recourse project financeprojects, (ii) structured financing transactions that share characteristics with project finance, (iii) otherfinancial institutions who are forming a significant part of the project applying IFC PerformanceStandards, and (iv) other projects recognized as appropriate.
In addition, if there is a relevant section of the Environmental, Health, and Safety Guidelines (EHS
Guidelines) of the World Bank Group, JBIC will confirm whether the projects meet that section, and thesestandards will be consulted as benchmarks in accordance with the Common Approaches.
Where appropriate, JBIC also refers to standards established by other international financial institutions,other internationally recognized standards, and/or standards or good practices established by developed
countries such as Japan as benchmarks.
However, since the natural environment, and the social and cultural background vary depending on countries
and regions, it is considered not necessarily appropriate to apply a uniform standard to all the projects.

3.2

Q. What are the World Bank ESSs and the IFC Performance Standards, of which JBIC ascertains whether
a project meets the relevant aspects?
A. Specifically, they are as follows.
World Bank ESSs
・ Assessment and Management of Environmental and Social Risks and Impacts (ESS1)・ Labor and Working Conditions (ESS2)
・ Resource Efficiency and Pollution Prevention and Management (ESS3)・ Community Health and Safety (ESS4)
・ Land Acquisition, Restrictions on Land Use and Involuntary Resettlement (ESS5)
・ Biodiversity Conservation and Sustainable Management of Living Natural Resources (ESS6)
・ Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities(ESS7)・ Cultural Heritage (ESS8)
・ Financial Intermediaries (ESS9)
・ Stakeholder Engagement and Information Disclosure (ESS10)IFC Performance Standards
・ Assessment and Management of Environmental and Social Risk and Impacts (PS1)・ Labor and Working Conditions (PS2)・ Resource Efficiency and Pollution Prevention (PS3)15

・ Community Health, Safety, and Security (PS4)・ Land Acquisition and Involuntary Resettlement (PS5)・ Biodiversity Conservation and Sustainable Management of Living Natural Resources (PS6)・ Indigenous Peoples (PS7)・ Cultural Heritage (PS8)

3.3

Q. What kinds of international standards and good practices could be used as a reference for environmental
and social considerations in the Environmental Guidelines?
A. JBIC recognizes that at present, there is no international standard that embraces all issues necessary
for confirming environmental and social considerations and may be applicable throughout the world. JBIC
has made reference to international treaties, the standards of international organizations other than theWorld Bank and IFC, standards and regulations in other advanced countries such as Japan, the U.S. andEuropean countries(Note). Although there are many standards and good practices JBIC may turn to, specificexamples are shown below.
(1) Pollution prevention/abatement
・ Regulation standards in Japan and in the U.S.
・ MARPOL Convention(2) Natural Environment
・ World Heritage Convention
・ Ramsar Convention
・ Washington Treaty
・ The Red List of IUCN
(3) Social Environment
・ World Heritage Convention
・ Guidelines on Resettlement of DAC(4) Specific Sectors
・ The Convention on Nuclear Safety and the relevant aspects of International Atomic Energy Agency(IAEA) standards
・ World Commission on Dams (WCD) Report, etc.
As it is difficult to enumerate all standards and good practices, including those not listed above, theEnvironmental Guidelines states comprehensively in Part 1. 3. (4) 3) that “Where appropriate, JBIC also
refers to standards established by other international financial institutions, other internationally recognized
standards, and/or standards or good practices established by developed countries such as Japan as
benchmarks.” If new standards are internationally established in the future, JBIC intends to use them as
reference as well.
(Note) In the Environmental Reviews of JBIC, World Bank ESSs and IFC Performance Standards are used
for checking. Therefore, the Environmental Guidelines places importance on them not as “a reference” but
as “meeting”.

3.4

Q. When acts, regulations and standards on social and environmental considerations established by thegovernment (including local governments) of the country in which the project is located are lax comparedwith their international counterparts, how does JBIC respond?
16

A. The Environmental Guidelines sets forth in Section 3-(4) of Part I, that if after comparison with various
standards and good practices such as the World Bank ESSs and IFC Performance Standards, “If JBIC
believes the environmental and social considerations of the project substantially deviate from thesestandards and good practices, it will consult with the host governments (including local governments),
borrowers, and project proponents to confirm the background and rationale for such deviation, and themeasures to rectify it if necessary.”
As a result of such effort, “If, as a result of its environmental reviews, JBIC judges that appropriate
environmental and social considerations are not ensured, it will encourage the project proponent throughthe borrower to undertake appropriate environmental and social considerations.” (Section 3-(5), Part 1)
However, as different countries and regions have varying natural environments as well as social and cultural
backgrounds, such factors must be taken into account.

3.5

Q. How are the results of environmental reviews being used in the decision-making of JBIC and in thefunding agreements?
A. The results of environmental reviews are used in making decisions on funding operation, for example,
reflecting them in the funding agreement. As set forth in Section 6 of Part 1, JBIC is making the utmost
effort to ensure that the following requirements are met through the agreements, depending on the natureand content of the project:(1) Reporting monitoring results;(2) Discussions with stakeholders when a problem arises;(3) Agreements with the host government and others when they have an important role to play; and(4) Conditions leading to the suspension of disbursements and other actions.

3.6

Q. The provisory clause of Part 1, Section 6 (1) of the Environmental Guidelines states that “in exceptional
cases where, given the nature of the project, documents necessary for environmental reviews are notavailable at the time that a decision on the funding must be made, JBIC may make a decision on the fundingon the condition that it will undertake the environmental reviews after decision making.” In what case andin what procedures is this clause applied?
A. Applicable examples of projects considered are acquisition of rights and interests in the early stages ofnatural resource development projects, or equity participation projects in which decision making is requiredin the stages where specific use of funds is not determined.
In these cases, JBIC will classify the categories of the project being planned based on the information
obtained from project proponents. If the project is classified as Category A or B, environmental and social
considerations are ascertained in the following processes.
[Before Decision Making]Although sufficient materials are not obtainable for conducing environmental reviews, arrangements onenvironmental and social considerations are ascertained to the extent possible based on the information
obtained from the project proponents. The information used for confirmation is disclosed to the public tothe extent possible in addition to the information written in the screening form, while taking account ofconfidential matters in business. Also, even if it is a temporary result, the results of confirmation ofenvironmental and social considerations are made public at the website immediately after decision making.
JBIC will explicitly stipulate in the loan agreement that development will not be made in the project until
environmental reviews are conducted.
[After Decision Making]
When documents necessary for environmental reviews, including Environmental and Social Impact
Assessment reports and environmental permit certificates issued by the host governments or otherappropriate authority (hereinafter collectively referred to as “ESIA reports and permit certificates”) are17

obtained, usual environmental reviews are conducted. The ESIA reports and permit certificates used forenvironmental reviews and the results of environmental reviews are made public at the website as usual.
In the case that appropriate environmental and social considerations are not confirmed in the above
environmental reviews, JBIC suspends funding disbursement and demands prepayment to the borrowers
based on the loan agreement.

3.7

Q. What are review procedures for Category FI?
A. To ensure that practically the same level of environmental and social considerations are made forCategory FI projects as for projects in other categories, the Environmental Guidelines set forth in Section
4-(3), Part 1, “JBIC checks through the financial intermediary etc. to see whether appropriate
environmental and social considerations as stated in the Guidelines are ensured for projects in thiscategory.”
Specific steps may include:(1) Identifying the implementation capacity of the financial intermediary for confirming the appropriatenessof environmental and social considerations and delegating to it such confirmation as stated in theEnvironmental Guidelines;(2) Requiring the financial intermediary to employ consultants to strengthen the institutional capacity for
confirming the appropriateness of environmental and social considerations, if JBIC determines that it does
not have a sufficient capacity for this task. Alternatively, once each sub-project is specified, JBIC will
confirm the environmental and social considerations; and(3) Making Category A sub-projects ineligible for funding
It is difficult to determine in advance what steps are most appropriate and JBIC has chosen to indicate
the basic principles above. The Environmental Guidelines stipulates that the results of environmental
reviews for Category FI projects should be published on the JBIC website at the signing of the funding
agreement.

3.8

Q. The Environmental Guidelines set forth, “consultation with stakeholders, such as local residents, musttake place after sufficient information has been disclosed. Records, etc. of such consultations must be
prepared.” (Section 2, Part 2) Will JBIC confirm whether consultations have taken place?
A. The Environmental Guidelines acknowledge the significance of dialogue with the local residents to ensure
appropriate environmental and social considerations.
In conducting environmental reviews, the Environmental Guidelines set forth in Section 3-(3), Part 1, “For
Category A projects, JBIC checks the extent of stakeholder participation and information disclosure being
undertaken for the project.”
The Guidelines further provide, “JBIC may conduct surveys of proposed project sites by dispatchingenvironmental experts to confirm environmental and social considerations if necessary.” JBIC will thus
confirm consultations with stakeholders.

3.9

Q. What issues will be considered with regard to gender, children’s rights, HIV/AIDS and othercommunicative diseases by JBIC under the Environmental Guidelines?
A. As the Environmental Guidelines are designed to assess natural and social environmental impacts ofindividual projects, JBIC will confirm the following issues for which consideration at the individual projectlevel is thought to be appropriate, such as gender, children’s rights, HIV/AIDS and other communicablediseases.

18

Firstly, for example, confirming gender consideration means that if the project involves resettlement, JBIC
will confirm whether a mechanism is in place for providing adequate respect for women’s opinions andviews and not excluding them.
Confirming considerations for children’s rights means that in the above project, JBIC will confirm whether
there are adequate preparations for schools and healthcare facilities for children at the relocated site.
Confirming considerations for communicable diseases such as HIV/AIDS means that if the project involves
large civil works and needs to set up a camp for workers, JBIC will confirm whether workers will receive
adequate guidance on communicable diseases.
Regarding the question over the scope of checks in these areas, since there is a great diversity in thenature of the projects, it is difficult to apply a uniform rule, and it is thus more appropriate to consider it
for specific projects.
Also, as a public agency, JBIC feels it should pay due respect to charters on human rights. In view of theirdiverse provisions and varying ratification status in different countries, the Environmental Guidelines
touched on them in the preface rather without making specific reference to them in the main text.

3.10 Q. In Part 2, Section 1. (3), “community health, safety, and security” is listed as one issue of the scope of
the project whose impact should be considered. What do you confirm, in particular, regarding the use of
security personnel in this respect?
A. In using security personnel, the Checklists stipulated “Are appropriate measures being taken to ensurethat security personnel involved in the project do not violate safety of other individuals involved, or local
residents?” as an item to be confirmed.
IFC Performance Standard 4 requires more specifically that the project proponents should meet
appropriately the following items, and the World Bank ESSs make generally similar requirements.
1) When the client retains direct or contracted workers to provide security,
・ Client assess risks posed by its security arrangements to those within and outside the project site.
・ In making such arrangements, the client will be guided by the principles of proportionality and goodinternational practice in relation to hiring, rules of conduct, training, equipping, and monitoring of such
workers, and by applicable law.
・ Client will make reasonable inquiries to ensure that those providing security are not implicated in past
abuses; will train them adequately in the use of force (and where applicable, firearms), and appropriate
conduct toward workers and Affected Communities; and require them to act within the applicable law.
・ Client will provide a grievance mechanism for Affected Communities to express concerns about the
security arrangements and acts of security personnel.
2) When the client uses government security personnel deployed to provide security services,・ Client will seek to ensure that security personnel will act in a manner consistent above.
・ Client will encourage the relevant public authorities to disclose the security arrangements for theclient’s facilities to the public, subject to overriding security concerns.

3.11 Q. In Section 1. (3) of Part 2 of the Environmental Guidelines, “While air could include greenhouse gases(GHG), specific requirements for environmental and social considerations on this issue are to be madebased on the Common Approaches”. What provisions exist in the Common Approaches? Let us also know
about the state of standards of international financial institutions used as benchmarks.
A. (1) Common Approaches
GHG is referred to in the Common Approaches as an example of “environmental impacts” of environmental
and social impacts to be specified in the passage “generation of significant air emissions, including
greenhouse gas emissions” (IV CLASSIFICATION, Paragraph 10). However, our understanding is that this19

does not require additional measures with respect to environmental reviews, monitoring and information
disclosure.
On the other hand, the Common Approaches set forth that Adherents shall continue to build a body ofexperience on the application of the Common Approaches through regular reporting and exchanges of
information, and as part of this proposition, the Common Approaches requires Adherents to report to theOECD Secretariat on the following (VIII REPORTING AND MONITORING OF THE RECOMMENDATION,
Paragraph 46).
・ The estimated annual greenhouse gas emissions from all fossil-fuel power plant projects
・ The estimated annual greenhouse gas emissions from other projects, where such emissions areprojected to be in excess of 25,000 tonnes CO2-equivalent annually and where the applicant or projectsponsor has provided the necessary information about the greenhouse gas emissions, e.g. via an ESIA
reportAlso, the Common Approaches require that, where relevant and feasible, it shall be tried to obtain and toreport the estimated annual direct and indirect greenhouse gas emissions (Scope I and Scope II
respectively) and/or the estimated annual direct greenhouse gas emissions (Scope 1) by carbon intensity
during the operations phase (VIII REPORTING AND MONITORING OF THE RECOMMENDATION, Paragraph
46).
The Common Approaches also list support for thermal power plants as one of the issues that requires
further consideration, and this will go further based on reporting of any actions taken to avoid, minimize
and/or offset CO2 emissions for all thermal power projects exceeding 700g/kWh emission intensity (VIIIREPORTING AND MONITORING OF THE RECOMMENDATION, Paragraph 47).
(2) International Standards used as benchmarks
IFC Performance Standard 3, which is one of the international standards used as a benchmark, makes thefollowing requirements for project proponents with respect to GHG emissions.
・ Client will consider alternatives and implement technically and financially feasible and cost-effective
options to reduce project-related GHG emissions during the design and operation of the project(Paragraph 7).
・ For projects that are expected to or currently produce more than 25,000 tonnes of CO2-equivalentannually, the client will quantify direct emissions from the facilities owned or controlled within thephysical project boundary, as well as indirect emissions associated with the off-site production ofenergy used by the project. Quantification of GHG emissions will be conducted by the client annuallyin accordance with internationally recognized methodologies and good practice (Paragraph 8).
Also, the World Bank ESS3 makes the following requirements to the borrower.
・ The Borrower will consider alternatives and implement technically and financially feasible and costeffective options to avoid or minimize project-related air emissions during the design, construction
and operation of the project (Paragraph 15).
・ As part of the environmental and social assessment, the Borrower will characterize and estimate
sources of air pollution related to the project. This will include an estimate of GHG emissions resulting
from the project, providing that such estimation is technically and financially feasible. (Paragraph 16).

3.12 Q. There is a phrase “associated facilities” in Part 2, Section 1. (3) of the Environmental Guidelines, what
facilities does it refer to?
A. The “associated facilities” has the same meaning as “associated facilities” defined in the Common
Approaches.
The associated facilities are those facilities that are not a component of the project but that would not be
constructed or expanded if the project did not exist and on whose existence the viability of the project
depends.

20

Such facilities may be funded, owned, managed, constructed and operated by the buyer and/or projectsponsor or separately from the project. When undertaking a review of associated facilities, JBIC should, toa reasonable extent, assess the potential environmental and social impacts of associated facilities, taking
into account the timing and location of their construction.

3.13 Q. In Part 2, Section 1 (6) of the Environmental Guidelines of JBIC, there is a clause which states “criticalnatural habitats including critical forest areas” and “natural habitats including natural forests.” Please
identify what areas they are. Also, please provide specific examples of “significant conversion ordegradation.”
A. Regarding “critical natural habitats including critical forest areas,” “natural habitats including naturalforests” and “significant conversion or degradation,” the following may be considered based oninternational standards used for benchmarks.
[See World Bank ESS6 (Paragraphs 21 and 23)]
1) Critical habitat
・ Habitat of significant importance to Critically Endangered or Endangered species, as listed in the IUCNRed List of threatened species or equivalent national approaches
・ Habitat of significant importance to endemic or restricted-range species
・ Habitat supporting globally or nationally significant concentrations of migratory or congregatory
species・ Highly threatened or unique ecosystems
・ Ecological functions or characteristics that are needed to maintain the viability of the four biodiversity
values described above
2) Natural habitat
・ Areas composed of viable assemblages of plant and/or animal species of largely native origin, and/or
where human activity has not essentially modified an area’s primary ecological functions and species
composition[See IFC Performance Standard 6 (Paragraphs 13 and 16 and Footnote 7)]1) Critical habitat
Critical habitats are areas with high biodiversity value, including
・ Habitat of significant importance to Critically Endangered and/or Endangered species;
・ Habitat of significant importance to endemic and/or restricted-range species;
・ Habitat supporting globally significant concentrations of migratory species and/or congregatory
species;・ Highly threatened and/or unique ecosystems; and/or
・ Areas associated with key evolutionary processes.
2) Natural habitat
・ Areas composed of viable assemblages of plant and/or animal species of largely native origin, and/or
・ Areas where human activity has not essentially modified an area’s primary ecological functions andspecies composition
3) Significant conversion or degradation
・ The elimination or severe diminution of the integrity of a habitat caused by a major and/or long-termchange in land or water use; or

21

・ A modification that substantially minimizes the habitat’s ability to maintain viable populations of its
native species

3.14 Q. When the project involves involuntary resettlement, how does JBIC confirm the consent of the local
inhabitants?
A. As set forth in Section 2 of Part 2, the Environmental Guidelines place a premium on appropriate
consultations with local residents. JBIC confirms, on the basis of the information provided by the borrower,
whether the consensus has been reached among the residents through the appropriate consultation
process. JBIC will make use of useful information provided not only by the borrower but also by the hostgovernment, private financial institutions cofinancing the project, and other stakeholders. As theEnvironmental Guidelines stipulate in Section 3-(3) of Part 1, “JBIC may conduct surveys of proposed
project sites by dispatching environmental experts to confirm environmental and social considerations if
necessary,” and it also confirms whether consultations with residents have been conducted properly.
In addition, as stated in the Environmental Guidelines, JBIC also confirm loss of means of livelihood in thesame way.

3.15 Q. In Section 1. (7) of Part 2 of the Environmental Guidelines, there is a clause which states “It is desirable
that the resettlement action plan includes elements required in the standard of international financial
institution which JBIC benchmarks.” Specifically, are the elements required by which standard?
A. The elements required are: ESS5 Annex 1 of the World Bank, if the World Bank ESSs are used as
benchmarks. And Guidance Note(Note) 5 Annex A of IFC Performance Standards, if the IFC PerformanceStandards are used as benchmarks. Specifically, confirm on websites of the World Bank and IFC.
(Note) Guidance for ensuring conformity with IFC Performance Standards
The minimum elements in ESS5 Annex 1 are as follows.
・ Description of the project・ Potential impacts
・ Objectives
・ Census survey and baseline socioeconomic studies
・ Legal framework・ Institutional framework
・ Eligibility
・ Valuation of and compensation for losses
・ Community participation
・ Implementation schedule・ Costs and budget
・ Grievance redress mechanism
・ Monitoring and evaluation
・ Arrangements for adaptive management
IFC Guidance Note Annex A generally set forth similar points

22

3.16 Q. In Section 1. (8) of Part 2 of the Environmental Guidelines, there is a clause which states “When aproject may have adverse impact on indigenous peoples’, various rights in relation to land and resources,
such rights must be respected in accordance with the spirit of the relevant international declarations andtreaties, and free, prior, and informed consents must be obtained.” What are the international declarations
and treaties relating to indigenous peoples?
A. The following declaration and convention correspond to the international declarations and treaties
relating to indigenous peoples. These are international documents pertaining to the rights of indigenous
peoples. However, they are not international standards such as the World Bank ESSs, with which JBIC
Guidelines require conformity.
・ United Nations Declaration on the Rights of Indigenous Peoples
・ Convention concerning Indigenous and Tribal Peoples in Independent Countries (International Labor
Organization (ILO) Convention No.169)

3.17 Q. Section 1. (8) of Part 2 of the Environmental Guidelines set forth that when a project may have any
adverse impact on the rights of indigenous peoples, “free, prior, and informed consents must be obtained.”
What kinds of procedures and consent are required?
A. When a project may have adverse impacts on indigenous peoples, sufficient consultations with them ortheir participation procedures must be taken based on information disclosure in a similar manner as in thecase of ordinary local residents (in Part 2 of the Environmental Guidelines, this point is set forth in Section
1. (5)). On the other hand, regarding the various rights that indigenous peoples have on their land andresources, “Free, Prior, and Informed Consent (FPIC))” is required in addition to such ordinary proceduresin light of their vulnerability.
Although there is no universally accepted definition of FPIC, we consider that it will be established throughgood faith negotiations between the project proponents and the affected communities of indigenous
peoples, in addition to usual consultations and procedures for participation. What is called “consent” here
does not necessarily require unanimity by all the participants and may be achieved even when individuals
or groups within the community explicitly disagree.
FPIC is required in the circumstances that the inherent rights of indigenous peoples are affected, as shown
below.
・ The circumstance that a project site is located on the lands traditionally owned and customarily used,
and that when natural resources are commercially developed on such land, adverse impact is expected
・ The circumstance that indigenous peoples are relocated from communally held lands and their natural
resources
・ The circumstance that a project may have significant impacts on their critical cultural heritage
This concept is in line with the interpretation of FPIC in IFC Performance Standard 7, and the World Bank
ESSs have a generally similar paragraph.

3.18 Q. In Section 1. (8) of Part 2 of the Environmental Guidelines, there is a clause which states “It is desirable
that the indigenous peoples plan include the elements required in the standard of international financial
institutions which JBIC benchmarks.” Specifically, what standards are required for the elements?
A. In the case that conformity with the World Bank ESSs is required to be confirmed, it points to thecontent of ESS7 Guidance Note of the World Bank, and that conformity with IFC Performance Standards
is required to be confirmed, it points to the content of Guidance Note(note) 7 Annex A. Specifically, checkwebsites of the World Bank and IFC.

The main points in ESS7 Guidance Note are as follows.
23

・ A summary of the Social Assessment
・ A summary of the results of the meaningful consultation (in the circumstances where FPIC is required,the outcome of the process of FPIC)・ A framework for meaningful consultation during project implementation
・ Measures for ensuring receipt of social and economic benefits that are culturally appropriate
・ Measures to avoid, minimize, mitigate, or compensate for potential adverse effects
・ The cost estimates, financing plan, schedule, and roles and responsibilities for implementing the plan・ Accessible procedures to address grievances
・ Mechanisms and benchmarks for monitoring, evaluating, and reporting
IFC Guidance Note 7 Annex A also set forth generally similar items.

3.19 Q. In the case that a project has a significant impact on the residents living around the project site, should
JBIC listen to the voices of potentially affected residents in a field study conducted at the project site asa part of its environmental reviews?
A. The project proponent is the main actor conducting environmental and social considerations in the
project, and JBIC is in the position of confirming its actions for considerations. It is unequivocally the
project proponent that responds to stakeholders, including the residents affected by the project. JBIC
confirms through environmental reviews whether appropriate response is made.
As part of such confirmation procedure, JBIC may make a case-by-case judgment and listen to the voicesof the affected residents when recognizing it necessary, in cases where a significant impact reaches theaffected residents in projects that involve large-scale involuntary resettlement or areas where indigenous
peoples are living around, or in cases where the stakeholders directly send their opinions to JBIC.

24

4.Monitoring
4.1

Q. What is the purpose of monitoring?
A. JBIC conducts monitoring to ascertain that the project proponent makes appropriate environmental andsocial considerations. Monitoring is also carried out in order to contribute to the early detection of initiallyunforeseen adverse impacts. Therefore, when a problem is identified through monitoring, JBIC promptly
informs the borrower and urges him to take an appropriate action.
The Environmental Guidelines stipulates in Section 1 (9) of Part 2 “It is desirable, after a project begins,
the project proponents monitor … and that they then take appropriate measures based on the results ofsuch monitoring.” It further provides that in the case a problem is identified as a result of monitoring, JBIC
“may ask the project proponent to take appropriate action through the borrower” (Section 4-(4), Part 1),
thereby addressing unforeseen impacts.

4.2

Q. Why do the Environmental Guidelines not stipulate in advance items requiring monitoring and themonitoring period?
A. The Environmental Guidelines are based on an idea that monitoring plays an important role in checking
whether the measures have been implemented as initially planned, whether the initial plan itself was
sufficient, and whether any unexpected external changes have had adverse effects on the environment.
JBIC thus confirms the results of monitoring conducted by the project proponents for Category A and B
projects.
JBIC does not think it appropriate to determine in advance, across the board, which items need to bemonitored and for how long. They are decided after considering various factors including the sector, natureand characteristics of the project and conditions in surrounding areas.
The main items requiring monitoring are considered as follows:・ Permits and approvals, explanations, and consultations (Response to matters indicated by authorities,
response to complaints from residents and other matters)
・ Anti-pollution measures (Air quality and water quality etc.)
・ Natural environment (Ecosystems: Impact on valuable species, countermeasures, etc.); and・ Social environment (Resettlement etc.)
These are laid out in advance under “Items Requiring Monitoring” in Section 6 of Part 2 in theEnvironmental Guidelines.
Monitoring will be carried out in accordance with an agreement reached with the borrower on the frequency
of monitoring and items requiring monitoring.

4.3

Q. Are studies of proposed project sites JBIC conducts for monitoring different from field studies
implemented already?
A. Monitoring results are submitted by the project proponent. As stipulated in Section 4-(4) of Part 1 in
the Environmental Guidelines, where necessary, JBIC may conduct its own field study. To date JBIC has
carried out such field studies while consulting with outside experts when necessary and intends to continue
to do so in the future.

4.4

Q. It is important to conduct monitoring appropriately. What specific measures is JBIC taking to strengthen
the environmental monitoring system?
25

A. Checking monitoring is recognized as important for confirming whether planned measures have beensteadily implemented, whether these measures are adequate, and whether any unforeseen changes in theexternal conditions are causing adverse impacts on the environment. As such, JBIC has been making efforts
to strengthen the system for checking monitoring.
For example, in some projects, third party environmental consultants have evaluated environmental
monitoring conducted by the project proponent.

4.5

Q. How long is the monitoring period? Even when it is clear that project operation is appropriate, isn’t it
inefficient to continue monitoring that project?
A. It is appropriate to determine the monitoring period for each project in accordance with the nature of
the project, the seriousness of potential environmental impacts, uncertainties and other factors.
When JBIC confirms that the project is operated properly in light of the nature and actual conditions of
the project and the sector it belongs to, JBIC’s check of monitoring will be simplified or brought to an end
after a certain period of time in order to achieve operational efficiency.

4.6

Q. Doesn’t JBIC conduct monitoring for sub-projects of Category FI projects?
A. Regarding the environmental reviews or monitoring conducted when sub-projects of Category FI projects
are categorized as A or B, either JBIC itself or financial intermediaries conduct them, depending on thecapabilities, experience and stance of the financial intermediaries.
When financial intermediaries conduct environmental reviews or monitoring, JBIC ascertains information on
sub-projects for which investments or loans are provided through financial intermediaries and, where
necessary, receives reports from the financial intermediaries, etc.

4.7

Q. Won’t JBIC give encouragement once a project is classified as “Category C”?
A. Yes, we will. In Section 1 “JBIC’s Basic Policies Regarding Confirmation of Environmental and Social
Considerations” of Part 1, the Environmental Guidelines stipulate that “JBIC makes the utmost efforts toensure that appropriate environmental and social considerations are undertaken in accordance with thenature of the project for which JBIC provides funding as stated in the Guidelines, through such means asagreements for funding (hereinafter referred to as “funding agreements”). Over a certain period of time
following funding decisions, JBIC will if necessary monitor or take steps to encourage borrowers and relatedparties to ensure that appropriate environmental and social considerations are undertaken.” Also, in Section
6 “Decision-making and Funding Agreements” of Part 1, they stipulate that “If JBIC considers that a
project is likely to have an adverse impact on the environment due to inappropriate environmental andsocial considerations, it will encourage through the borrower the project proponent to undertake appropriate
environmental and social considerations.” These stances apply regardless of the categories of projects;
JBIC is to, if necessary, take steps to encourage borrowers and related parties to ensure that appropriate
environmental and social considerations are undertaken for Category C projects also, in accordance withthe above-mentioned stipulations.

26

5.Information disclosure
5.1

Q. What is the concept upon which the provisions pertaining to information disclosure in the Environmental
Guidelines is based?
A. The provisions on information disclosure in the Environmental Guidelines were established in order tostrike a good balance between two principles: information disclosure and maintaining business
confidentiality. Disclosure of information is very important for ensuring that the project proponent issustainably implementing and managing considerations for the environment and society, and for JBIC toensure accountability in the applicable funding activities. On the other hand, for example, in an industrial
plant project, a special production process embodies significant proprietary corporate knowledge, andtherefore in private business in particular, adequate considerations for its confidentiality are required.

5.2

Q. Environmental Guidelines state “JBIC endeavors to achieve further disclosure of information byencouraging project proponents”. Especially, what information do you endeavor to disclose?
A. JBIC endeavors to achieve further disclosure of information regarding environmental consideration,
including translations of Environmental and Social Impact Assessment reports in Japanese and English
versions or the monitoring result by project proponents.

5.3

Q. Are information disclosure provisions of the Environmental Guidelines in line with the Common
Approaches?
A. The provisions on information disclosure in JBIC’s Environmental Guidelines are in line with the Common
Approaches. For example, the Common Approaches state the disclosure of environmental information suchas Environmental and Social Impact Assessments for Category A projects in advance of funding decisions
and the disclosure of environmental information after funding decisions such as “subject to the legal
provisions on public disclosure in Members’ countries, Members should make available to the public at
least annually environmental and social information on projects classified in Category A and Category B”.

5.4

Q. Where does information disclosure under the Environmental Guidelines stand in relation to information
disclosure under the “Act Concerning Disclosure of Information Possessed by Independent Administrative
Institutions” (the “Information Disclosure Act”)?
A. JBIC determines whether or not it should disclose information it possesses under the Information
Disclosure Act, upon request from the public for disclosure.
In contrast, under the Environmental Guidelines, JBIC provides, on its own, important information onscreening and environmental reviews, thereby increasing the transparency of its business operations aswell as encouraging third parties including related agencies and stakeholders to provide information. This
will help materialize and expand the intentions of the Information Disclosure Act.

5.5

Q. How did JBIC disseminate information on the preparations and content of the Environmental Guidelines
to the domestic public?
A. The Environmental Guidelines are available not only by a pamphlet in the head office of JBIC but also
on its website.
In confirming the appropriateness of environmental and social considerations for individual projects, thefollowing information is provided at the time of screening: project name, country, place, project outline,
sector, category classification and the reasons for classification. After signing the agreement of loan and27

investment, the results of environmental reviews are made available at the JBIC website, and JBIC plans
to continue actively disclosing information in this way.

5.6

Q. Based on the Environmental Guidelines, what kind of information regarding individual projects is madeavailable to the public on the JBIC website?
A. The following information will be disclosed on the JBIC website before the signing of a funding agreement:
project name, country, location, an outline and sector of the project, and its category classification, as wellas the reasons for that classification (Section 5-(2), Part 1). For Category A and Category B projects, JBIC
promptly makes available on the JBIC website the status of acquirement of the Environmental and Social
Impact Assessment reports and environmental permit certificates issued by the host governments or otherappropriate authority, which are stated to be collectively referred to as “ESIA reports and permit
certificates” in Section 4 (3) “Environmental Reviews for Each Category”, Part 1 of the Environmental
Guidelines, as well as the ESIA reports and permit certificates themselves. This is based on a stance that
ESIA reports, which are in accordance with the environmental impact assessment systems of the hostcountry, are generally to obtain approval (environmental permits and approvals) of the country.
In addition to the ESIA reports and permit certificates, JBIC promptly makes available on its website thestatus of acquirement of documents that are available to the public in the host country (and of documentsthat the project proponent consented be made available on the website) as well as such documents
themselves among those obtained by JBIC from the borrowers and related parties for confirming
environmental and social considerations. The documents obtained by JBIC from the borrowers and relatedparties for confirming environmental and social considerations will include documents available forenvironmental and social confirmations in such cases as that there are no environmental impact
assessment systems of the host country, that there are environmental impact assessment systems but
ESIA reports will not be produced because the project is not subject to the systems, and that JBIC judgesthat additional information is required for confirming environmental and social considerations while theproject is subject to the systems and ESIA reports have been produced, as well as resettlement actionplans, livelihood restoration plans, indigenous peoples plans, etc. depending on the project.
After executing a funding agreement, JBIC provides the results of its environmental reviews and screening
on the website, so it is possible to view the basis on which JBIC conducted its decision-making, from theinformation supplied relating to environmental and social considerations.
However, JBIC pays due consideration to the confidentiality of the commercial and other matters of theborrowers and related parties, taking into account the competitive relationships of private businesses.
※Information Disclosure on Confirmation of Environmental and Social Considerations

5.7

Q. Will the name of the project company be disclosed as part of information disclosure?
A. Information disclosure covers: “project name, country, location, an outline and sector of the project, andits category classification, as well as the reasons for that classification.” The name of the specific projectcompany will not be disclosed, as this is often regarded as commercially confidential information.

5.8

Q. Isn’t it inappropriate to exempt some information from disclosure on the ground of business
confidentiality?
A. Regarding the projects conducted by private companies under market competition, it is essential inreflection of this fact, to make considerations for business confidentiality. For example, in an industrial
plant project, a special production process is a significant asset and source of competitive strength, andtherefore deserves special considerations for its confidentiality.
Thus in disclosing information, JBIC feels it is important to strike a balance between the principles of
information disclosure and business confidentiality, and only proceed with active disclosure after
recognition of this fact.
28

5.9

Q. What is the timing of information disclosure on the screening information?
A. Regarding the timing of disclosure for screening information, the Environmental Guidelines stipulate “It
endeavors to make such disclosure well in advance of the decision-making.” (Section 5-(2) 2), Part 1)
Based on this, the information is disclosed as promptly as possible following a tentative decision on categoryclassification.
For JBIC to make the aforementioned category classification, the screening form has to be submitted by
the borrower. The screening form is submitted when the following two conditions are fulfilled: a loan request
has been submitted to JBIC; and adequate information may be obtained to conduct screening.

5.10 Q. Given the provision, “It endeavors to make such disclosure well in advance of the decision-making”(Environmental Guidelines Part 1 Section 5-(2)2)) at what timing will decisions be made?
A. The timing of “the decision-making” corresponds to the time at which a funding agreement between
JBIC and the borrower is signed.

5.11 Q. How long are disclosure periods for the results of screening and environmental reviews for projects?
A. It is difficult to set a uniform disclosure period for the screening information of projects. This is because
JBIC gets involved in projects at different timings and there is the need to respond flexibly to developmentin private business deals.
For Category A projects that are likely to have a significant adverse environmental impact, however, JBIC
draws on examples of other countries and is thus making an effort to disclose information on screening
results for about 45 days. No disclosure period is set for results of environmental reviews.

5.12 Q. Will ESIA reports and permit certificates on Category A projects be disclosed in Japan as well?
A. Information on whether JBIC obtained ESIA reports and permit certificates required for Category A
projects or not is available on the JBIC website. In addition, ESIA reports and permit certificates themselves
may be made available after appropriate steps have been taken, including excluding portions touching oncommercially confidential information.

5.13 Q. In Section 5-(2) of Part 1 of the Environmental Guidelines, there is a clause which states, “documents
other than ESIA reports and permit certificates … obtained from the borrowers and related parties forconfirming environmental and social considerations”. What kinds of documents does this refer to?
A. There are a variety of possible names, contents and formats, depending on the characteristics of eachproject.
This is not an exhaustive list, but documents considered here could include, for example, environmental
management plans, resettlement action plans, including where necessary, livelihood restoration plans (inprojects in which large scale involuntary resettlement or large scale loss of means of livelihood occurs),
and indigenous people’s plans (in projects which have an effect on indigenous peoples).
In the event that translations of such documents including the ESIA report and permit certificates are
obtained from the borrowers and related parties, these are also applicable.

5.14 Q. In Section 5. (2) 2) of Part 1 of the Environmental Guidelines, there is a clause which states “The statusof acquirement of documents other than ESIA reports and permit certificates, and such documents
obtained from the borrowers and related parties for confirming environment and social considerations if
29such documents are publicly available in the host country.” Even if the borrower and related parties
consent, won’t JBIC make such information and documents available, for any status of their publicavailability in the host country?
A. Section 5 (2) 1) of the Environmental Guidelines states that “JBIC endeavors to achieve further
disclosure of information by encouraging project proponents.” In addition to the ESIA reports and permit
certificates, JBIC will make available on its website the documents obtained by JBIC from the borrowers
and related parties for confirming environmental and social considerations, if the project proponents
consent that the documents be available on the website.

5.15 Q. In many cases, the local residents affected by the project have no access to the JBIC website. How
can these people obtain information on the project?
A. JBIC’s methods of disclosure are not limited to the use of the website. The Environmental Guidelines
stipulate, in Section 1 (5) of Part 2, that conducting “sufficient consultations with stakeholders” at the
project site is one of the basic principles of environmental and social considerations required for JBICfinanced projects. In this way, JBIC ensures adequate disclosure of information to the local residents.

5.16 Q. Can’t the findings of environmental reviews be disclosed at an early date?
A. In some projects, based on the results of environmental reviews, the funding agreement may include
conditions having important bearing on environmental and social considerations. From this point of view,
JBIC discloses the findings of environmental reviews as soon as possible after the signing of a funding
agreement, whereby JBIC informs to the external world that it has formally made a funding commitment.

5.17 Q. Why doesn’t JBIC make available to the public ex-ante evaluation reports for the projects?
A. The summary of environmental reviews conducted by JBIC will be made public after a funding agreement
is signed.

5.18 Q. Will the details of the funding agreement be made public after its signing?
A. JBIC actively makes public, information pertaining to environmental and social considerations inaccordance with the Environmental Guidelines. However, its confidentiality obligation as a financial
institution prevents JBIC from disclosing funding agreements.

5.19 Q. Is any information disclosure stipulated in the Environmental Guidelines, relating to monitoring?
A. The Environmental Guidelines set forth in Section 5 (2) 3) “Information disclosure after signing of funding
agreements” of Part 1 that “For Categories A and B projects, results of the monitoring conducted by the
project proponents to the extent they are made public in the host country”. However, JBIC will makeavailable on its website the results of the monitoring conducted by the project proponents if the project
proponents consent that the results be made available on the website. Also, Section 1 of Part 2 of theEnvironmental Guidelines states that “It is desirable that project proponents make the results of themonitoring process available to project stakeholders,” thus encouraging project proponents to take action.

30

6.ESIA reports and permit certificates and other essential information
6.1

Q. From what sources is information on projects concerning the environment collected?
A. JBIC collects environmental information relating to projects, through its being provided by the borrower.
Also, the Environmental Guidelines stipulate that information from the stakeholders is welcome.
In confirming the appropriateness of environmental and social considerations, information provided not onlyby the borrower but also by other sources is considered important. Efforts are being made to collectinformation from sources other than the borrower through on-site studies, and JBIC plans to continue
these efforts into the future.

6.2

Q. In Section 2 of Part 2 of the Environmental Guidelines, there is a clause which states “It is desirable
that ESIA reports cover the items stipulated in the Common Approaches.” Given that, which part of theCommon Approaches stipulates those items?
A. The items to be covered in ESIA reports are stipulated in Annex II of the Common Approaches and theexamples are as follows.
ANNEX IIENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) REPORT 1
An Environmental and Social Impact Assessment (ESIA) report focuses on the significant issues of a project. The
report’s scope and level of detail should be commensurate with the project’s potential impacts and risks, and should
address the issues set out in the international standards applied to the project in accordance with paragraphs 20-24of this Recommendation. The ESIA report typically includes the following items (not necessarily in the order shown):1.

Non-technical executive summary: concisely discusses significant findings and recommended actions in lay
language.

2.

Policy, legal, and administrative framework: discusses the policy, legal, and administrative framework within which
the Assessment is carried out, including host country regulations, including obligations implementing relevantinternational social and environmental treaties, agreements, and conventions, the international standards applied
to the project, as well as any additional priorities and objectives for social or environmental performance
identified by the buyer/project sponsor. Explains the environmental requirements of any co-financiers.

3.

Project description: concisely describes the proposed project and its geographic, ecological, social, health andtemporal context, including any additional project components that may be required (e.g. dedicated pipelines,
access roads, power plants, water supply, housing, and raw material and product storage facilities). Encompasses
facilities and activities by third parties that are essential for the successful operation of the project. Normally
includes maps showing the project site and the project’s area of influence.

4.

Baseline data: assesses the dimensions of the study area and describes relevant physical, biological,
socioeconomic, health and labour conditions, including any changes anticipated before the project commences.
Also takes into account current and proposed development activities within the project area but not directly
connected to the project. Data should be relevant to decisions about project location, design, operation, or
mitigation measures. The section indicates the accuracy, reliability, and sources of the data.

5.

Environmental and Social impacts: predicts and assesses the project’s likely positive and negative impacts, inquantitative terms to the extent possible. Identifies mitigation measures and any residual negative impacts thatcannot be mitigated. Explores opportunities for enhancement. Identifies and estimates the extent and quality ofavailable data, key data gaps, and uncertainties associated with predictions, and specifies topics that do not
require further attention. Evaluates impacts and risks from associated facilities and other third party activities.
Examines global, transboundary, and cumulative impacts as appropriate.

6.

Analysis of Alternatives: compares reasonable alternatives to the proposed project site, technology, design, andoperation in terms of their potential environmental and social impacts; the feasibility of mitigating these impacts;
their capital and recurrent costs; their suitability under local conditions; and their institutional, training, and31

monitoring requirements. States the basis for selecting the particular project design proposed and justifies
recommended emission levels, including where relevant for greenhouse gases, and approaches to pollution
prevention and abatement.
7.

Management Programme: consists of the set of mitigation and management measures to be taken during
implementation of the project to avoid, reduce, mitigate, or remedy for adverse social and environmental impacts,in the order of priority, and their timelines. May include multiple policies, procedures, practices, and management
plans and actions. Describes the desired outcomes as measurable events to the extent possible, such as
performance indicators, targets or acceptance criteria that can be tracked over defined time periods, andindicates the resources, including budget, and responsibilities required for implementation. Where thebuyer/project sponsor identifies measures and actions necessary for the project to comply with applicable laws
and regulations and to meet the international standards applied to the project, the management programme will
include an Action Plan, which is subject to disclosure to the affected communities and on-going reporting andupdating.

8.

Appendices:・

List of ESIA report preparers – individuals and organisations.

・References – written materials, both published and unpublished, used in study preparation.

・

Record of interagency and consultation meetings, including consultations for obtaining the informed views of theaffected communities and/or their legitimate representatives and other interested parties, such as civil society
organisations. The record specifies any means other than consultations (e.g. surveys) that were used to obtainthe views of affected groups.

・Tables presenting the relevant data referred to, or summarised in, the main text.

・

Associated reports, audits, and plans (e.g. Resettlement Action Plan or Indigenous Peoples/Natural Resource
Dependent Community plan, community health plan).

・Action Plan that (i) describes the actions necessary to implement the various sets of mitigation measures orcorrective actions to be undertaken, (ii) prioritises these actions, (iii) includes the time-line for theirimplementation, and (iv) describes the schedule for communicating with affected communities when on-goingdisclosure or consultation is expected.

(Note) This Annex is based on the IFC Guidance Notes: Performance Standards on Social andEnvironmental Sustainability of 31 July 2007; however, for the purposes of this Recommendation, the text
has been adapted.

6.3

Q. JBIC’s Environmental Guidelines stipulate that ESIA reports and permit certificates should be released
to the public. Are there any countries where this is legally forbidden?
A. To the knowledge of JBIC, there are no countries which prohibit the disclosure of ESIA reports andpermit certificates under act, while some countries do not have provisions for disclosure stipulated in theiracts. When a project arises in a country which does not obligate the disclosure of ESIA reports and permit
certificates, JBIC actively encourages the project proponents to voluntarily do so.

6.4

Q. Could demanding the disclosure of an ESIA report or a permit certificate by ignoring the domestic
institutional setup of host country constitute interference with the domestic affairs of that country?
A. JBIC considers it important to disclose ESIA reports and permit certificates for achieving sustainableprojects consistent with environmental preservation. In the Environmental Guidelines this is set forth as“required”. Concerned parties understand this point, once it has been explained to them.
On the other hand, there are some countries which do not disclose information at present in the actual
project process, although disclosure is not prohibited by law. This may be based on a difference in thenotion of “information disclosure” rather than a problem in the ESIA system.

32

Therefore, JBIC must increase opportunities for consultation in the future, to obtain the understanding ofconcerned parties.

6.5

Q. Is the information sought in the Environmental Guidelines from borrowers relating to the environment
actually available?
A. Yes, it is basically available for JBIC. In most cases, the borrowers have conducted studies appropriately,collected relevant information on potential environmental impacts of their projects and taken measures toaddress them.

6.6

Q. Suppose a third party provides to JBIC, information of little credibility whose validity it cannot establish
in an effort to thwart the project. What kind of information will JBIC deal with and how?
A. JBIC is basically receptive to information from third parties. Of the information it receives, JBIC confirms
the appropriateness of environmental and social considerations of that which is significant and assured asreliable, after which it uses it as reference.
With the diversity of information that comes to JBIC’s attention, spending considerable time and cost to
confirm information of low credibility for which the source cannot be specified would be undesirable in viewof the efficient operations required for a policy-based financing institution. Therefore, JBIC would like torequest that when third parties provide information, they provide factual and accurate information whoseveracity they can demonstrate.

6.7

Q. The Section 4. (4) of Part 1 of the Environmental Guidelines set forth, “The information necessary formonitoring needs to be supplied by the borrower and related parties by appropriate means.” In the casethat the borrowers do not participate in project management, they do not have access to information,either. Even then, do the borrowers still have an obligation to supply information?
A. When the borrowers do not participate in project management, it is common for the information available
to them to be restricted, and as such JBIC feels it unrealistic to insist on information gathering across theboard. Consequently, we would like to give due consideration to ensure that our information gathering
activities will not harm business relations between the borrowers and the project proponent.

33

7.Application and Review of the Environmental Guideline
7.1

Q. What is the process through which the Environmental Guidelines that is in effect from July 2022 wererevised?
A. For the current Environmental Guidelines, firstly the status of implementation of the former
Environmental Guidelines was verified and investigated, in accordance with Section 8 of Part 1 “Application
and Review of the Guidelines” of the former Environmental Guidelines (effective April 2015), the results ofwhich were compiled into a report and published.
Then, since it is stipulated in the former Environmental Guidelines that “When making revisions, JBIC willseek the opinions of the Japanese Government, the governments of developing countries, Japanesecompanies, experts, NGOs etc., while maintaining transparency in the process”, consultation forums whichcalled for participation from the general public were held a total of 10 times between February 2021 andFebruary 2022. With a large number of attendees from industry, NGOs, experts, and concerned government
ministries and agencies, discussion was carried out on the various points, based also on the results of theaforementioned verification and investigation of the status of implementation. This resulted in theformulation of a revision draft proposal for the Environmental Guidelines.
Effort was made to ensure transparency of the revision process, and disclose information, which included
making the minutes of the aforementioned meetings, and the distributed materials available on the JBIC
website when applicable.
In addition, public comments on the aforementioned revision draft proposal were invited for a period of one
month approximately, and the Environmental Guidelines were revised based also on the valuable opinionsof the public received in this way.

7.2

Q. Given that the revised Environmental Guidelines came into full force in July 2022, are they applied tothe projects for which funding requests are made after that time?
A. JBIC applies the revised Environmental Guidelines to the projects for which substantive funding requests
have been received in July 2022 and later. The term substantive funding request used here means thesubmission of the request and the screening form to JBIC.

7.3

Q. Will the Environmental Guidelines be periodically revised in the future?
A. As stipulated in Section 8 of Part 1 of the Environmental Guidelines, a comprehensive review of theEnvironmental Guidelines will be conducted after five years have passed, and with that result, revisions
may then be made as needed.
However, the revision could be made to the guidelines when JBIC deems it necessary to be in line with therevised Common Approaches, without waiting for the periodic review. In this case, the guidelines will berevised while maintaining transparency in the process. As a concrete procedure, JBIC will make theguidelines revision plan open to the public and create the opportunity to accept the stakeholders’ opinions
through holding the briefing sessions and public comments to the revision plan.

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8.Other
8.1

Q. Does an English version of the Environmental Guidelines exist?
A. Among JBIC’s borrowers are many foreign companies, governments, and government agencies. The
English translation, therefore, has been available for their convenience. If there is any ambiguity in the
English version and/or any inconsistency with Japanese version, the Japanese version prevails.

8.2

Q. What is FAQ?
A. FAQ or “frequently-asked questions” were prepared for the Environmental Guidelines in order to draw
together and help solve the questions and concerns of many concerned parties. If you find it difficult tounderstand the Environmental Guidelines, it may help to read it in combination with the FAQ.

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