MODULE 4: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE (ESS10)

Module 4: Stakeholder Engagement and Information Disclosure (ESS10)

ENTER

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 MODULE 4: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE (ESS10)

Topic: Welcome
Topic: Scope of Application and Requirements
Topic: Stakeholder Engagement
Topic: Stakeholder Engagement During Project Preparation
Topic: Stakeholder Engagement During Project Implementation
Topic: Grievance Mechanisms
Topic: Stakeholder Engagement in Other Standards
Topic: Summary

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Read More

This course aims to provide an in-depth introduction to the elements of the

World Bank’s Environmental and Social Framework for Investment Project
Financing. Before taking this course, you are encouraged to read the
Environmental and Social Framework itself and to use it as a reference
document as needed, both while taking the training and in the future.

This course was developed for World Bank staff and therefore some
references may be specific to World Bank staff.

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Introduction to the Module

Welcome to Module 4 - The Environmental and Social Standard on

Stakeholder Engagement and Information Disclosure (ESS10).

This module will cover the following topics:

 Objectives of ESS10
 Scope of Application and Requirements
 Stakeholder Engagement during Project Preparation
 Stakeholder Engagement during Project Implementation
 Grievance Mechanisms

Completion time: Approximately 30-40 minutes

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 MODULE 4: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE (ESS10)

Learning Objectives
By the end of this module, you will be able to:
 Describe why Borrowers should engage with stakeholders
 Define the two types of stakeholders
 Discuss in detail what is required from the Borrower at each stage of
the project regarding stakeholder engagement and information
disclosure
 Describe the key elements of a Stakeholder Engagement Plan
 Detail the requirements for a grievance mechanism
 Describe specific requirements for stakeholder engagement and
information disclosure found in other Environmental and Social
Standards

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Objectives of ESS10
ESS10 and its objectives are aimed at establishing a systematic, open and
transparent engagement between the Borrower and project stakeholders
throughout the life of the project.

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Identify all stakeholders.

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Assess the level of support for the project among stakeholders.

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Promote and provide ways for stakeholder views to be part of:

 Project design
 Environmental and social performance

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Ensure effective and inclusive engagement of all stakeholders, including

those needing special measures or assistance.

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Disclose information on environmental and social risks and impacts and

proposed mitigation measures to stakeholders in a timely and accessible
manner.

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Provide project-affected parties with an inclusive and accessible grievance

mechanism.

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Definition of Stakeholders
Who are stakeholders?
 Project-affected parties: Those who are, or are likely to be, affected by
the project
 Other interested parties: Those who may have an interest in the project
and who could, for example:
o Influence the opinions of affected parties either positively or
negatively
o Affect the implementation process or the sustainability of the
project’s outcomes

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Stakeholders
The stakeholders of a project will vary depending on the details of the
project.

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Project-affected Parties
Project-affected Parties refers to both intended beneficiaries of the project
and those likely to be affected by the project because of actual impacts or
potential risks to their physical environment, health, security, well-being or
livelihoods. These stakeholders may include individuals, groups, or local
communities.

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Other Interested Parties

Other Interested Parties refers to any individual, group or organization with
an interest in the project, which may be because of the project location, its
characteristics, its impacts or matters related to public interest. For
example, these parties may include regulators, government officials and
civil society organizations.

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World Bank Teams’ Responsibilities

 Provide overall guidance to Borrowers so that they can develop a
meaningful stakeholder engagement process that is tailored to the risks
and impacts and concerns of stakeholders.

Examples:
 Provide advice on methodologies, appropriate timing and
documentation processes
 Monitor the implementation of stakeholder engagement
o Monitoring could include participating in the consultation activities
in person or through a third party

 Depending on the potential significance of environmental and social

risks and impacts, require the Borrower to retain independent third party
specialists to assist in the stakeholder identification and analysis

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The World Bank Participation in Consultations

The World Bank staff may participate in consultation activities to get a first-
hand understanding of the context and any concerns of project-affected
parties and other interested parties, and how effectively the Borrower will
address them. However, the World Bank staff need to be sure that
stakeholders understand that projects belong to the government and not
the World Bank.

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Why is Stakeholder Engagement Essential?

Stakeholder engagement is critical to projects because it can:
 Increase stakeholder understanding and build support for, and
ownership of, projects
 Improve project design
 Contribute to successful project implementation
 Improve the environmental and social sustainability of projects
The nature, scope and frequency will be proportionate to the nature and
scale of the project and its potential risks and impacts

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What is Stakeholder Engagement?

Stakeholder engagement:
 Is an ongoing process that continues through the life of the project
 Goes beyond providing information and answering questions
 Should begin as early as possible and continue through the life of the
project
The nature, scope and frequency will be proportionate to the nature and
scale of the project and its potential risks and impacts.

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Begin Stakeholder Engagement as Early as Possible

It is much easier to establish a good working relationship early in the
process, before misunderstandings have crept in, rather than to try to fix a
relationship that is already damaged. Similarly, where consultations lead to
changes in project design, it is easier and more efficient to incorporate
these at an early stage.

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Elements of Stakeholder Engagement

The main elements of stakeholder engagement are:
 Carrying out stakeholder identification and analysis
 Planning how engagement with stakeholders will take place
 Disclosing information
 Consulting with stakeholders
 Addressing and responding to grievances
 Reporting to stakeholders

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What the Environmental and Social Assessment Should Include

The environmental and social assessment process should include a
documented record of the stakeholder engagement carried out during
development of the project, including:
 A description of the stakeholders consulted
 A summary of the feedback received
 A brief explanation of how the feedback was taken into account, or the
reasons why it was not

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Stakeholder Engagement should be Proportionate

For example, the engagement process for a dam construction in a heavily
populated valley with good arable land is likely to be more intensive than
the engagement process for construction of a school.

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Identification and Analysis of Different Stakeholders

The Borrower undertakes stakeholder identification and analysis to help
determine the level and type of communication and engagement that are
appropriate for the project.
Steps include:
 Identifying stakeholders
o Distinguishing between project-affected parties and other
interested parties
o Identifying project-affected parties that may be disadvantaged or
vulnerable
o Identifying individuals or groups with different concerns about and
priorities related to the project’s impacts, mitigation mechanisms
and benefits and may require different forms of engagement
 Assessing identified stakeholders and determining their levels of
influence and interests in the project
 Assessing how, when and on which topics to engage stakeholders

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Disadvantaged or Vulnerable Project-affected Parties

Disadvantaged or vulnerable project-affected parties refer to those who
may be more likely to be adversely affected by the project’s impacts and/or
more limited than others in their ability to take advantage of a project’s
benefits. Such an individual/group is also more likely to be excluded
from/unable to participate fully in the mainstream consultation process and
as such may require specific measures and/or assistance to do so. This
will take into account considerations relating to age, including the elderly
and minors, and including in circumstances where they may be separated
from their family, the community or other individuals upon which they
depend.

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Forms of Engagement
Forms of engagement include:
 Public meetings
 Community meetings
 Individual interactions
 Focus group discussions
 Standing committee meetings
 Questionnaires/Household surveys
 Participatory processes, for example, seasonal mapping, community
mapping, community transects, participatory rural appraisal
Engagement techniques applied may vary from project to project.

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Why Project Information Disclosure is Essential

Disclosing project information is essential for meaningful consultation on
project design and for stakeholders to understand:
 The potential opportunities of the project
 The risks and impacts of the project
The Borrower should provide the following information to stakeholders as
early as possible, to enable meaningful consultations with stakeholders on
project design:
 The purpose, nature and scale of the project
 The duration of proposed project activities
 Information from the environmental and social assessment process,
regarding potential risks and impacts of the project on local
communities, including:
o Proposals for mitigating risks and impacts
o Potential risks and impacts that might disproportionately affect
vulnerable and disadvantaged groups
o Description of differentiated measures taken to avoid and
minimize disproportionate risks and impacts

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 The proposed stakeholder engagement process, highlighting ways in

which stakeholders can participate and contribute during project design
and/or implementation
 The time and venue of proposed public consultation meetings, and the
process by which meetings will be notified, summarized and reported
 The process and means by which grievances can be raised and
addressed

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Forms of Project Information Disclosure

 The Borrower ensures information is accessible to stakeholders
o Accessibility means:
 Stakeholders can obtain and understand project information in
a way and form that is appropriate to them
 The needs of specific groups, such as the disabled or the
illiterate, or those speaking different languages from the
majority, are taken into consideration
o Examples of accessible disclosure include:
 Project environmental and social documents translated into
local language(s)
 Pictures on poster boards
 Leaflets written in non-technical language
 Oral presentations with question and answer sessions
 A combination of all of the above
 The Borrower should publicize the fact and location of disclosed
information in a way that will reach all relevant groups and individuals
o Locations where project information can be disclosed include:

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 City and/or village halls

 Public libraries
 Local print media
 Radio shows
 Public meetings
 Homes of stakeholders
 Web-based channels to reach broader audiences
 Stakeholder engagement should be proportionate to the nature and
scale of the project and its potential risks and impacts

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Meaningful Consultations
Meaningful consultation is essential and it is a two-way process that:
 Provides stakeholders with opportunities to express their views on
project risks, impacts and mitigation measures and allows the Borrower
to consider and respond to them
 Begins early in the project planning process and continues on an
ongoing basis, particularly when new risks or impacts arise
 Encourages stakeholder feedback to inform project design and help
identify and mitigate risks and impacts and considers and responds to
such feedback
 Is based on the prior disclosure and dissemination of relevant, objective,
meaningful and accessible information
 Supports active and inclusive engagement with project-affected parties
 Is free of external interferences
 Is documented and disclosed by the Borrower

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Overview of a Stakeholder Engagement Plan

A Stakeholder Engagement Plan (SEP):
 Documents the process of stakeholder engagement
 Sets out when and how the Borrower will engage with stakeholders
throughout project Preparation and Implementation
 Distinguishes between project-affected parties and other interested
parties
 May differentiate with regard to the level and nature of engagement
appropriate for different stakeholders
 Is developed and implemented by the Borrower in consultation with the
World Bank and with input from stakeholders
 Is proportionate to the nature and scale of the project and its potential
risks and impacts
 May be a stand-alone document or part of the Environmental and
Social Commitment Plan, depending on the nature and scale of project
risks and impacts
Requirements for stakeholder engagement in other Environmental and
Social Standards should be addressed in the SEP.

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Topics Included in a Stakeholder Engagement Plan

Topics in a Stakeholder Engagement Plan include:
 Timing and methods of communication and engagement through the
project life-cycle
 Range and timing of information to be communicated to and sought
from stakeholders
 Measures to remove obstacles to participation, including for the
vulnerable or disadvantaged
 How the views of differently affected groups will be captured
 A grievance mechanism
Select here to learn important notes for Stakeholder Engagement Plans.

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 It is important to ensure that the schedule and budget allocated for

stakeholder engagement is sufficient to involve differently affected
groups to ensure that they can participate effectively
 When stakeholder engagement depends on community representatives
such as village heads, clan heads, community and religious leaders,
local government representatives, civil society representatives,
politicians or teachers, then the Borrower will make a reasonable effort
to verify that these representatives do represent views of the individuals
and communities and that they facilitate the communication process
appropriately

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Disclosure of the Stakeholder Engagement Plan

 The draft Stakeholder Engagement Plan (SEP) should be disclosed as
early as possible, and before project appraisal
 Whenever material changes are made, the revised SEP should be
disclosed
 Stakeholders should be informed of new versions of the SEP

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The Stakeholder Engagement Framework

A Stakeholder Engagement Framework:
 May be used in certain circumstances, depending on the level of project
information available
 Outlines general principles and a collaborative strategy to identify
stakeholders and plan for the engagement process, once the necessary
information is available

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Stakeholder Engagement is an Ongoing Process

During project implementation, the Borrower:
 Continues stakeholder engagement in accordance with the Stakeholder
Engagement Plan
 Seeks feedback on the project's performance and implementation of the
Environmental and Social Commitment Plan
 Provides information in cases of significant changes and consults with
affected parties on how risks/impacts will be mitigated
 Discloses any updates to the Environmental and Social Commitment
Plan
 Designates personnel responsible for implementing and monitoring
stakeholder engagement

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Overview
The Grievance Mechanism:
 Allows stakeholders to register grievances, concerns, suggestions,
inquiries, and complaints
 Supports submission of grievances at multiple locations and through
multiple mechanisms
 Is accessible to all stakeholders regardless of their social, cultural, or
economic standing
 Where feasible and suitable, may use existing formal and informal
grievance mechanisms, supplemented as needed
 Should be proportionate to the nature of the project and the potential
risks and impacts of the project

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Grievances and Concerns

Grievance mechanisms may be used by stakeholders to raise a wide
range of issues, from someone complaining about construction noise or
property damage caused by blasting, someone asking how to get a job on
the project, or someone complaining that they were not included on a list of
people to be compensated.

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Accessibility
The grievance mechanism should be readily accessible to all project-
affected parties, at no cost and without retribution. For example:
 An inaccessible grievance mechanism would be in a location that is not
reachable for particular groups of stakeholders, such as women or
people who live in remote areas
 An accessible grievance mechanism would enable anonymous
complaints to reduce the risk of retribution

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Key Elements
The grievance mechanism should:

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Address concerns and handle grievances promptly and effectively and in a

transparent and culturally appropriate manner.

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Be discreet, objective, sensitive and responsive to the needs and concerns

of the project-affected parties.

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Allow access to judicial or administrative remedies.

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Allow anonymous complaints to be raised.

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Include a log for registering and tracking grievances and actions taken.

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Discovery Question
The grievance mechanism established as part of the Stakeholder
Engagement Plan may be utilized under the Land Acquisition, Restrictions
on Land Use and Involuntary Resettlement (ESS5) and Indigenous
Peoples/Sub-Saharan African Historically Underserved Traditional Local
Communities (ESS7).
Correct Choice

X True

False

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ESS10, Paragraph 26 Footnote 9

The grievance mechanism to be provided under ESS10 may be utilized as
the grievance mechanism required under other Standards (ESS5 and
ESS7). However, the grievance mechanism for project workers required
under ESS2 will be provided separately.

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Discovery Question
Which of the following are acceptable options if resolution of grievances
has not been achieved or affected parties are not satisfied with the
proposed resolution?
Correct Choice

X The Borrower may provide mediation

X Referral to an appeals process such as the national judiciary

The stakeholder who submitted the grievance is asked to

withdraw it, and this is duly recorded

The implementing agency ignores the grievance until the

specified time for response has expired

There are no acceptable options as all grievances must be

resolved in a manner satisfactory to the stakeholders before the
project closes

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ESS10 Annex 1 Paragraphs 2-3

The grievance mechanism may include the following:
a) Different ways in which users can submit their grievances, which
may include submissions in person, by phone, text message, mail,
e-mail or via a web site
b) A log where grievances are registered in writing and maintained as a
database
c) Publicly advertised procedures, setting out the length of time users
can expect to wait for acknowledgement, response and resolution of
their grievances
d) Transparency about the grievance procedure, governing structure
and decision makers
e) An appeals process (including the national judiciary) to which
unsatisfied grievances may be referred when resolution of grievance
has not been achieved
The Borrower may provide mediation as an option where users are not
satisfied with the proposed resolution.

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How to Submit Grievances

Ways in which grievances can be submitted include:
 In person
 Through intermediaries
 Phone
 Fax
 Text message
 Mail
 Email
 Through social media
 Through a website

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Information Dissemination
Dissemination of information on the grievance process:
 Project-affected parties should be informed by the Borrower about the
grievance process as part of stakeholder engagement.
 A record of responses to grievances should be disclosed.
 Procedures, such as response times, appeals processes, and so on,
should be publicly advertised.
 Information on the procedure, governing structure and decision makers
should be available.

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Discovery Question
According to ESS10, a new grievance mechanism should be setup
specifically for the project and to avoid issues that are often associated
with pre-existing systems, such as discrimination, gender imbalance, elite
capture, and/or lack of confidence in local officials.
Correct Choice

True

X False

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ESS10, Paragraph 13 Footnote 4

Where possible, stakeholder engagement will utilize engagement
structures within the national system, e.g., community meetings,
supplemented as needed with project-specific arrangements.

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Stakeholder Engagement References in Other Environmental and

Social Standards
Several of the other Environmental and Social Standards include specific
references, explicit requirements or special provisions for stakeholder
engagement.

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Highlights in ESS1 - Assessment and Management of Environmental and

Social Risks and Impacts:
 Stakeholder engagement is an integral part of the environmental and
social assessment
 Results of stakeholder engagement are taken into account in the
Environmental and Social Commitment Plan
 Information on stakeholder engagement will be reported on regularly by
the Borrower as part of project performance monitoring
 Additional stakeholder engagement is carried out if the Borrower’s
framework is changed in a manner inconsistent with the Environmental
and Social Commitment Plan and appropriate changes will be proposed
to the World Bank

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Highlights in ESS2 - Labor and Working Conditions:

 An additional grievance mechanism, separate from that required under
ESS10 for all stakeholders, will be provided for all direct workers and
contracted workers so that they can raise workplace concerns

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Highlights in ESS4 - Community Health and Safety:

 Based on the results of a risk hazard assessment, the Borrower will
prepare an Emergency Response Plan in coordination with the relevant
local authorities and the affected community

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Highlights in ESS5 - Land Acquisition, Restrictions on Land Use and

Involuntary Resettlement:
 Community Engagement includes the following Borrower obligations
o Engaging with affected communities, including host communities
o Disclosing relevant information
o Ensuring meaningful participation of affected communities during
consideration of alternative project designs and throughout the
planning, implementation, monitoring and evaluation of the
compensation process, livelihood restoration activities and
relocation process
o Ensuring special attention is given to women’s perspectives and
preferences are obtained
 The Borrower will ensure that a grievance mechanism is in place as
early as possible in project development

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Highlights in ESS6 - Biodiversity Conservation and Sustainable

Management of Living Natural Resources:
 For project areas that are legally protected, designated for protection or
regionally or internationally recognized, the Borrower will consult and
involve protected area sponsors and managers, project-affected parties
including Indigenous Peoples and other interested parties in planning,
designing, implementing, monitoring and evaluating the proposed
project
 Stakeholders and qualified experts will be involved when the Borrower
is considering the development of a biodiversity offset as part of the
mitigation strategy
 For projects that involve forest harvesting operations conducted by
small-scale producers or by local communities, the Borrower will ensure
that the operations have achieved a standard of sustainable forest
management developed with the meaningful participation of project-
affected parties including Indigenous Peoples

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Highlights in ESS7 - Indigenous Peoples/Sub-Saharan African Historically

Underserved Traditional Local Communities:
 Involving their representative bodies and organizations
 Providing sufficient time for their decision-making processes
 Allowing for their effective participation in the design of project activities
or mitigation measures that could affect them either positively or
negatively

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Highlights in ESS8 - Cultural Heritage:

 Consultation with stakeholders is needed to identify and to consider the
significance of cultural heritage that may be affected by the project and
to explore avoidance and mitigation options
 Project-affected parties participate in making a determination as to
whether disclosure of information regarding cultural heritage would
compromise or jeopardize its safety or integrity
 Where a project site contains or prevents access to a previously
accessible cultural site, the Borrower will consult with users of the site
to allow continued access to it
 The Borrower will consult project-affected parties regarding natural
features with cultural heritage significance affected by the project
 The Borrower will not proceed with commercial use of cultural heritage
without carrying out meaningful consultation with stakeholders and
providing for fair and equitable sharing of benefits

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Highlights in ESS9 - Financial Intermediaries:

 A Financial Intermediary’s Environmental and Social procedures should
require FI subprojects to conduct stakeholder engagement in a manner
proportionate to the risks and impacts of the subproject

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 MODULE 4: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE (ESS10)

Recap
Here is a quick recap of the main points covered in this module.
 Stakeholders
 Borrower
 Information Disclosure
 Grievance Mechanism

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 MODULE 4: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE (ESS10)

Stakeholders
 There are two types of stakeholders, project-affected parties and other
interested parties
 Stakeholder engagement can increase stakeholder understanding and
build support for and ownership of projects
 Stakeholder engagement is critical to improve project design and
successful project implementation
 Effective and inclusive engagement makes it possible for communities
to provide input into project design and mitigation measures

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 MODULE 4: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE (ESS10)

Borrower
 The Borrower undertakes stakeholder identification and analysis
 The Borrower should assess identified stakeholders and determine their
levels of influence and interests in a project
 Stakeholder identification and analysis helps determine the level and
type of communication and engagement that is appropriate for a project

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 MODULE 4: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE (ESS10)

Information Disclosure
 Disclosing project information is essential to help stakeholders
understand the potential opportunities of a project and the risks and
impacts of a project
 The Borrower should disclose and publicize information in a way that
will reach all relevant groups and individuals
 Meaningful consultation is a two-way process that provides
stakeholders with opportunities to express their views on project risks,
impacts, and mitigation measures, and allows the Borrower to consider,
and respond to them

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 MODULE 4: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE (ESS10)

Grievance Mechanism
 The Grievance Mechanism allows stakeholders to register grievances,
concerns, suggestions, inquiries, and complaints
 The Grievance Mechanism is accessible to all stakeholders regardless
of their social, cultural, or economic standing
 The Grievance Mechanism addresses concerns and handles
grievances promptly and effectively and in a transparent and culturally
appropriate manner
 Project-affected parties should be informed by the Borrower about the
grievance process as part of stakeholder engagement

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