U.S. Position on the African Development Bank Group’s Integrated Safeguards System (ISS) 

December 2013

The United States (U.S.) welcomes and supports Management’s proposal for an Integrated 

Safeguard System (ISS). The proposal is a marked improvement from the existing safeguards, 

reflecting a multiyear assessment and consultation process, including outreach to development 

assistance practitioners, national governments, civil society organizations, and the private sector. 

The U.S. was pleased to see the broad public consultation process, careful consideration of 

public input and Board views, and diligent efforts to find consensus that maintains a high bar on 

difficult issues. The resulting ISS represents a major step for the African Development Bank 

(AfDB) and, consequently, for the people of Africa.

Safeguards at the multilateral development banks (MDBs), including the AfDB, are an essential 

tool for avoiding or mitigating environmental and social risks in Bank-financed projects and 

programs. The new ISS reflects the African Development Bank Group’s commitment to go 

beyond risk mitigation, and use its resources and knowledge to help achieve best practices for 

promoting environmental and social sustainability and sound development outcomes. 

The U.S. believes the new ISS, as written, can substantially strengthen the ability of the AfDB 

and its borrowers and clients to advance the vision of the Bank’s new Ten Year Strategy (2013-

2022), which focuses on inclusive and green growth. The U.S. welcomes the AfDB’s 

application of the ISS to all AfDB operations in both the private and public sectors, noting that 

all policy-based loans will now be subject to due diligence, as will regional, country, and sector 

strategies. The U.S. is also very pleased that assessments of associated facilities and cumulative 

impacts will be required. 

With respect to the five Operational Safeguards, the U.S. believes the greater clarity, coherence 

and consistency across the range of substantive areas will serve the Bank and its borrowers and 

clients well. Among the improvements over the current safeguards, the U.S. highlights the 

addition of the groundbreaking attention to climate change considerations and the requirement of 

an assessment of gender issues for every project. The U.S. is also pleased with the protections 

for labor conditions and workers’ rights, increased attention to vulnerable persons (including 

those associated with indigenous peoples or those with disabilities), and sensitivity to the 

particular problems involving critical habitats. The U.S. welcomes the new greenhouse gas 

(GHG) emissions tracking tool and hopes the Bank succeeds in finalizing this tool by end-2015, 

as expected. 

The U.S. also welcomes the addition of assessments and requirements related to the social 

aspects of AfDB-financed projects and programs. Though human rights are not directly raised as 

a stand-alone issue, the AfDB can help ensure that its lending activities do not contribute to 

human rights violations or abuses through its social assessments and requirements, such as the 

requirements related to persons with disabilities and workers’ rights. This would be consistent 

with member countries’ commitments and obligations under the International Human Rights 

Covenants and the African Charter of Human and Peoples’ Rights. With regard to the proposed 

preamble, the U.S. understands the Bank’s statement to reflect the fact that the promotion of 
human rights—including economic, social, and other rights as articulated in International Human 

Rights Covenants—is consistent with the Bank’s mandate as set forth in Articles 1 and 38 of the 

Bank Agreement. 

With respect to indigenous peoples, the U.S. believes the AfDB should promote the territorial 

rights, traditional economies, cultural integrity, and traditional knowledge of indigenous peoples 

and human rights of indigenous persons. There are important provisions in the ISS for 

indigenous peoples and their members, including on consultation, broad community support, 

cultural heritage, traditional knowledge, resettlement, labor, and non-discrimination. However, 

the U.S. would have far preferred to see a stand-alone operational safeguard on indigenous 

peoples to provide the strongest possible protections. The U.S. strongly urges and expects the 

Bank to continue to strengthen and address specific issues linked to indigenous peoples in the 

Environmental and Social Impact Procedures (ESAPs) and the Integrated Environmental and 

Social Impact Assessment (IESIA) guidance notes. For example, there is no explicit recognition 

in the proposed ISS that indigenous peoples may collectively own land, cultural heritage, and 

other resources, and the U.S. urges that this gap be addressed in the ESAPs and IESIA guidance 

notes. The U.S. also encourages the Bank to implement robustly its commitment to continued 

dialogue with indigenous peoples on how to support their development throughout the entire 

lifecycle of Bank projects.

In the area of disclosure, the U.S. welcomes the introduction of the new Integrated Safeguards 

Tracking System. It is important that affected communities and other stakeholders have 

complete access to information on complex issues with sufficient time to review and react, while 

recognizing the need for business confidentiality. The U.S. urges the Bank to follow the practice 

at other MDBs and make available automatically the full Environmental and Social Impact 

Assessments (ESIAs) on the new system.

The U.S. strongly supports the additional attention to critical habitats. Given the risk of 

irreversible damage to these precious resources, it is essential that the Bank be on solid scientific 

ground before agreeing to any projects in or affecting critical habitats. Moreover, given the 

complexity of ecosystems and the risks associated with human activities in critical habitats, the 

U.S. sees no compelling case for ever allowing the use of offsets for impacts in critical habitat.

With respect to the Environmental, Health and Safety (EHS) Guidelines, the U.S. suggests it be 

clarified that the technical standards of the EHS Guidelines (or, where appropriate, more 

protective standards) be included in the ESIA and their impacts evaluated, not deferred to the 

management plan.

Approval of the new ISS document is only an intermediary step on the path to a robust 

safeguards system. The immediate next step is for the AfDB to draft the ESAPs and the IESIA 

guidance notes, which should serve to strengthen the operational safeguards and provide more 

detailed guidelines for ensuring that project proposals include, among other things, robust 

baseline data and comprehensive alternatives assessments. The U.S. looks forward to further 

discussions with the AfDB during the development of these guidance notes. 
The U.S. also underscores the importance of the Bank’s role in oversight and capacity building:

the U.S. expects strong engagement by the Bank with its borrowers and clients on these 

safeguard priorities throughout the project cycle. The U.S. also believes it is critical for the Bank 

to engage in meaningful consultations with affected communities, workers’ organizations, and 

other stakeholders, not only during project preparation, but during project implementation as 

well. The AfDB should welcome third-party monitoring to complement its own supervision 

system. It is essential that the AfDB develop and implement more robust procedures for 

supervision, monitoring, reporting, and evaluation. 

Finally, to live up to its potential, the Bank’s effort must be sufficiently resourced. The U.S.

welcomes the discussion of staffing in the Board paper. Management’s commitment to helping 

Africa address complex environmental, labor, and social challenges will only succeed with the 

necessary staff and financial resources to operationalize the policy, the operational safeguards

(OSs), procedures, and guidance notes.