Adaptive risk management Approach to monitoring E&S compliance and changes to the project during implementation Enforcement is weak in Indonesia. WB should be more active to make sure the safeguards and new ESSs are enforced. This will help the implementers to perform better and to make a more inclusive policy in general for the government of Indonesia. Disclose monitoring data and have watch dogs to check enforcement in order to ensure E&S compliance. Risk classification Approach to determining and reviewing the risk level of a project Screening (and monitoring) of projects should be better defined. ESS1 Assessment and management of environmental and social risks and impacts Assessment and nature of cumulative and indirect impacts to be taken into account Treatment of cumulative and indirect impacts when identified in the assessment of the project Establishing project boundaries and the applicability of the ESSs to Associated Facilities, contractors, primary suppliers, FI subprojects and directly funded sub-projects Circumstances under which the Bank will determine whether the Borrower will be required to retain independent third party specialists Third party monitoring for E&S issues should be required during project design and implementation. A challenge is to properly integrate environmental and social aspects during the project life cycle (i.e. assessment, management during implementation, monitoring and evaluation, etc.). The proposed ESF could be clearer about the role of the ESSs in each phase of a project. Environmental and Social Commitment Plan (ESCP) Legal standing of the ESCP and implications of changes to the ESCP as part of the legal agreement No feedback ESS2 Labor and working conditions Definition and necessity of and requirements for managing labor employed by certain third parties (brokers, agents and intermediaries) Application and implementation impacts of certain labor requirements to contractors, community and voluntary labor and primary suppliers A participant asked if ESS2 would provide any kind of supervisory means to monitor and enforce labor standards. There is a lot of exploitation in the current system, including the restriction of free labor association. ESS2 brings an opportunity but a robust system should be put in place to make the requirements of this standard operational. Some participants noted that the issue of child labor is currently under the Ministry of Welfare’s domain but it should apply to all sectors. ESS2 should help prevent child labor through a continuous dialogue process. Protection of child labor is a basic human right. This is a major issue in Indonesia and the challenges are extraordinary.
be provided to the Board to inform its decision Criteria for establishing and implementation of Free, Prior and Informed Consent (FPIC) Comparison of proposed FPIC with existing requirements on consultation Application of FPIC to impacts on Indigenous Peoples’ cultural heritage ESS8 Cultural Heritage Treatment of intangible cultural heritage Application of intangible cultural heritage when the project intends to commercialize such heritage Application of cultural heritage requirements when cultural heritage has not been legally protected or previously identified or disturbed No feedback ESS9 Financial Intermediaries Application of standard to FI subprojects and resource implications depending on risk Harmonization of approach with IFC and Equator Banks The success of the use of FI and application of ESS9 depend on establishing a system to identify appropriate FI (one participant expressed that many FI in Indonesia have dubious history in relation to environmental issues). Information sharing is also key for success. What kind of system will be in place to ensure information disclosure? Who will do it and how much will be disclosed? ESS10 Stakeholder engagement Definition and identification of project stakeholders and nature of engagement Role of borrowing countries or implementing agencies in identifying project stakeholders One participant stressed the importance of consulting local communities for all development projects, paying particular attention to use of the right forums to consult with minority groups. Grievance redress mechanism (GRM): The details of the process are needed. For example, where does the grievance mechanism begin within the project cycle? Where do we go to complain? How long does it take to respond? What is the third party mechanism to manage complaints? Routine social dialogues between the WB and CSOs are needed to collect the concerns and resolve them, especially labor issues.