Comments on the European Bank for Reconstruction and Development (EBRD) Draft Public Information Policy
20 May 2011
The revised EBRD Public Information Policy (PIP) adopts few of the proposals submitted during in the first stage of commenting by NGOs. We believe that this represents a significant lost opportunity for the Bank to improve its draft and insist that the detailed comments submitted in January should be further considered by the EBRD before drafting its final PIP. These comments concentrate on several priority issues, in addition to those submitted in January.
In particular, the draft is excessively referential to confidentiality, to the detriment to its openness principles. As a primary step, it needs to incorporate the Aarhus Convention into its activities. It also needs to increase the amount of information in affirmative disclosure including project level documents, environmental information, environmental and social covenants, risk assessments, and board votes and documents. In addition, the public interest test should be improved to fully reflect the multiple information needs of the public better. Finally, the Bank should join multi-stakeholder initiatives such as the IATI and EITI and incorporate their policies into the PIP.
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