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Environmental & Social Review Summary
Project Number
26473
Company Name
BOGOTA DISTRITO CAPITAL
Date ESRS Disclosed
Oct 26, 2007
Country
Colombia
Region
Latin America and the Caribbean
Last Updated Date
Oct 17, 2025
Environmental Category
B - Limited
Status
Completed
Previous Events
Approved : Nov 29, 2007
Signed : Aug 28, 2008
Invested : Feb 1, 2010
Sector
Highway Operations (Includes Toll Roads)
Industry
Infrastructure
Department
Gbl Infrastructure & Natural Resources
Project Description
Bogota’s Institute for Urban Development (Instituto de Desarrollo Urbano or IDU), is a dependency within the Greater Municipality of the Capital District of Bogota which is dedicated to the development and maintenance of access and transport infrastructure. Among IDU’s primary goals and policies are:
- to contribute to a socially inclusive development of the Capital District by improving transportation and mobility;
- contributing toward improvement in productivity;
- promoting the use and enjoyment of public spaces; and
- enabling residential construction development.
The project involves a $50 million senior loan to the metropolitan municipality of Bogota Distrito Capital, to finance part of its 2008 capital expenditures program for periodic maintenance and rehabilitation of the City’s urban streets network. The loan is part of a $400 million financing package that includes in addition to the proposed IFC loan a recently completed successful $300 million international Peso-linked bond issue, and a $50 million loan being processed by the Andean Development Corporation (CAF). It is expected that the IFC and CAF loans and about $60 million from the bond will be dedicated to street rehabilitation, with the rest of the bond proceeds used for other capital expenditure program.
- to contribute to a socially inclusive development of the Capital District by improving transportation and mobility;
- contributing toward improvement in productivity;
- promoting the use and enjoyment of public spaces; and
- enabling residential construction development.
The project involves a $50 million senior loan to the metropolitan municipality of Bogota Distrito Capital, to finance part of its 2008 capital expenditures program for periodic maintenance and rehabilitation of the City’s urban streets network. The loan is part of a $400 million financing package that includes in addition to the proposed IFC loan a recently completed successful $300 million international Peso-linked bond issue, and a $50 million loan being processed by the Andean Development Corporation (CAF). It is expected that the IFC and CAF loans and about $60 million from the bond will be dedicated to street rehabilitation, with the rest of the bond proceeds used for other capital expenditure program.
Overview of IFC's Scope of Review
IFC reviewed a series of documents including:
Miscellaneous information describing the company’s environmental, health, and safety (EHS) management systems as well as corporate social responsibility programs, including:
- Environmental Management Guidelines for the Development of Infrastructure Projects in Bogota;
- Environmental Management Guidelines for Infrastructure Projects in Rural Areas of the Capital District;
- Description of Social Management Programs (PowerPoint presentation);
- Description of Social Management Programs for Land Acquisition (publication);
- Description of Social Management Programs for Construction Projects (publication);
- Land Acquisition Processes and Procedures (publication);
IFC interviewed environmental and social specialists at the Institute for Urban Development (IDU) including managers and key technical specialists of the Environmental Management Office and the Social Issues Management Office to evaluate IDU’s management systems and procedures and to understand how these are implemented.
Miscellaneous information describing the company’s environmental, health, and safety (EHS) management systems as well as corporate social responsibility programs, including:
- Environmental Management Guidelines for the Development of Infrastructure Projects in Bogota;
- Environmental Management Guidelines for Infrastructure Projects in Rural Areas of the Capital District;
- Description of Social Management Programs (PowerPoint presentation);
- Description of Social Management Programs for Land Acquisition (publication);
- Description of Social Management Programs for Construction Projects (publication);
- Land Acquisition Processes and Procedures (publication);
IFC interviewed environmental and social specialists at the Institute for Urban Development (IDU) including managers and key technical specialists of the Environmental Management Office and the Social Issues Management Office to evaluate IDU’s management systems and procedures and to understand how these are implemented.
E & S Project Categorization and Applicable Standard
While all Performance Standards (PS) are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:
The following seven (7) Performance Standards apply to the IDU project:
- PS1: Social and Environmental Assessment and Management Systems;
- PS2: Labor and Working Conditions
- PS3: Pollution Prevention and Abatement
- PS4: Community Health and Safety
- PS5: Land Acquisition and Involuntary Resettlement
- PS6: Biodiversity Conservation and Sustainable Natural Resource Management
- PS8: Cultural Heritage
Although there are indigenous lands located within the greater Capital District area, no projects are planned in these areas as part of the proposed investment. In the eventuality of a need for future construction in areas designated as indigenous lands, the company would follow applicable environmental permitting requirements, disclosing information on the impacts of such projects to those communities and consulting with them prior to project implementation. IDU would comply with the requirements of PS7, which would be incorporated in the company’s EMS.
The following seven (7) Performance Standards apply to the IDU project:
- PS1: Social and Environmental Assessment and Management Systems;
- PS2: Labor and Working Conditions
- PS3: Pollution Prevention and Abatement
- PS4: Community Health and Safety
- PS5: Land Acquisition and Involuntary Resettlement
- PS6: Biodiversity Conservation and Sustainable Natural Resource Management
- PS8: Cultural Heritage
Although there are indigenous lands located within the greater Capital District area, no projects are planned in these areas as part of the proposed investment. In the eventuality of a need for future construction in areas designated as indigenous lands, the company would follow applicable environmental permitting requirements, disclosing information on the impacts of such projects to those communities and consulting with them prior to project implementation. IDU would comply with the requirements of PS7, which would be incorporated in the company’s EMS.
This is a Category B project because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. A mature, established, operating entity, IDU has a proven track record of effective management of environmental and social impacts from its projects in compliance with applicable regulations at the national and district levels. IDU’s capacity to manage environmental and social risks has been significantly influenced through the supervision of the World Bank, which has financed IDU projects for over a decade, requiring IDU to comply with the World Bank’s Safeguard Policies. IDU devotes adequate financial and human resources to its environmental and social management programs effectively mitigating potential impacts from on-going operations.
Environmental and Social Mitigation Measures
- EHS Assessment and Management Systems
- Environmental and Social Assessment:
In the development of all new projects, IDU undertakes an environmental and social assessment of the aspects and impacts, both negative and positive, in the project’s zone of influence. The environmental and social assessment cycle begins at the earliest stage of the project planning effort, that is, during field surveys and pre-feasibility studies, where technically and financially feasible alternatives are examined. This process considers all potential impacts and applicable legal requirements of the various authorities with jurisdiction over social and environmental matters in the City of Bogota. Depending on the nature of the infrastructure development activities undertaken by IDU, additional authorities with jurisdiction over these projects may include various dependencies of the Greater Municipality of Bogota (Alcaldia Mayor) such as the Capital District’s Environmental Secretariat and various other public service corporations (i.e. Water and Sewer Service). The environmental assessments are typically the responsibility of contractors who must ensure that the assessment meet regulatory requirements to obtain the necessary environmental permits from the Environmental Secretariat. The social assessments involving land acquisition and involuntary resettlement include detailed socio-economic surveys and census which are normally conducted by personnel from IDU’s social management department and, depending on the size and complexity of the project, with the assistance of external contracted experts.
- Management Program:
Responsible environmental and social performance is embedded within the IDU’s mission, vision, and urban development strategy. IDU has established a robust environmental and social management program that aims to incorporate a series of functional elements and tools into the implementation of its environmental and social policy during the design, construction and maintenance of urban transport infrastructure. The elements of this program include clearly articulated objectives, strategies, assignment of responsibilities, supervision and audit programs, and a feedback mechanism for the review of environmental and social policies.
Comprising five key objectives, IDU’s written Environmental Policy aims to protect the environment through the rational use of renewable natural resources and through protection of worker and community health and safety by targeting the following objectives: incorporating environmental considerations as early as possible in the project planning phase and throughout the project life cycle; fostering an individual and collective change in the environmental conscience and commitment for compliance with environmental laws of managers, employees and contractors; collaborating with the monitoring work of the independent contractor oversight process (Interventoria); and achieving institutional and inter-institutional coordination.
Based on the results of the environmental and social impact assessments, IDU prepares the respective, project-specific management plans. Implementation of social management plans entailing land acquisition and resettlement are implemented by IDU, with the assistance of other government entities that provide complementary social services. Responsibility for the preparation of the implementation program for the environmental management plan (PIPMA) is assigned to the contractors responsible for the works according to the requirements of IDU’s environmental and social action programs and associated guidelines. The PIPMA specifies mitigation measures for various potential adverse impacts in the pre-construction, construction and operation phases of the project.
IDU has a complete package of guidelines and mandatory procedures to ensure proper environmental design, management and monitoring of infrastructure Works. Specifically, IDU has the following guidelines:
- Guidelines for Environmental Management of small and mid-size Infrastructure Works;
- Environmental Guidelines for Infrastructure Projects Design;
- Complement to Bogotá’s Green Manual, to ensure proper management of forest specimens;
- Guidelines for Occupational Health and Industrial Safety;
- Manual for Environmental Monitoring of Works; and
- Environmental Management Assessment and checklists.
The guidelines include programs for:
- camp site management;
- management of borrow materials and sites;
- management of wastes and disposal;
- traffic management;
- public participation;
- management of green areas;
- risk and occupational health and safety;
- management of drainage, pavements and concrete structures;
- management of chemicals, liquid waste, oils, and fuels;
- water management;
- management of equipment and machinery; and
- control of emissions and noise.
IDU has also recently developed a series of environmental, health, and safety guidelines specifically applicable to construction of road infrastructure in rural areas around the Capital. The rural guidelines include sections specifically designed for application of specific geographic areas and a matrix that can be used to determine the applicable of certain sections of the guidelines.
Although the most significant environmental and social impacts occur in the construction activities under IDU’s jurisdiction, IDU has also prepared an Institutional Environmental Management Plan (PIGA), as required by local regulations. Since early 2007, IDU has began to implement a series of internal environmental initiatives intended to increase the environmental conscience of its own staff across all departments and define and estimate the footprint of its own operations with regards to energy consumption, water consumption, waste generation, and wastewater discharges from its 1,400 employees located in various office buildings in Bogota.
IDU is targeting to complete the certification of its corporate environmental management system under the ISO 14,000 requirements by the end of 2007.
IDU has a social management program that addresses land acquisition and resettlement activities as well as community issues during the implementation of construction activities. The land acquisition and resettlement program has a combination of social ad economic components with the objective of obtaining comparable or improved conditions for resettled persons. The social component of the program includes a series of complementary processes and activities designed to provide social support associated with the design and implementation of resettlement plans including a social support process which provides potentially displaced individuals and families with a permanent source of information and operational support throughout resettlement activities (i.e. access to needed social services such as health, education, nutrition, supplemental income for families led by women, and special attention to vulnerable individuals, etc); real estate advice and search assistance; legal advice and assistance; and economic advice. The economic component of the social management program is designed in accordance with national and municipal compensation laws and IDU’s internal administrative requirements which determine the appropriateness of the financial compensation and which provides guidance on its effective use, especially in cases of economic displacement.
- Organization:
IDU has institutionalized its environmental guidelines and social action policies and has environmental and social management departments staffed with qualified specialists that have experience in managing the environmental and social impacts of its projects. Overall responsibility and authority for implementation of IDU’s environmental and social policies and programs lies with corporate environmental and social departments which provide a direct advisory service to the General Director’s office. Implementation of environmental and social programs is further supported by various departments within the Corporate Sub-Directorate, which is responsible for IDU’s internal administrative functions, and the Technical Sub-Directorate, which is responsible for various project implementation areas such as:
- project studies and design;
- land acquisition; and
- construction management.
The environmental and social departments are each led by their respective managers and staffed by interdisciplinary teams of specialists which include engineers, planners, lawyers, sociologist, and anthropologists.
Compliance of contractor’s implementation of the PIPMAs is ensured through the bidding documents and legal contracts which include and financial incentives. Contractors are required to have resident environmental and social supervisors and vegetation management specialists whose appointments for the specific project must be approved by IDU based on a series of minimum qualifications also outlined in the contract. Project implementation is continually supervised and audited by independent construction supervisors who conduct daily inspections used to create weekly scores of performance on the environmental and social contract requirements of the project. Weekly compliance scores are averaged on a monthly basis and then used to adjust the payment of a portion of the contract set aside as a budget for the implementation of environmental and social management plans. IDU, the contractor, and the independent project supervisors meet on a weekly to monthly basis to discuss the results of the evaluation and to modify the implementation program if required to address identified problems.
- Training:
IDU primarily has a supervisory and oversight role in the implementation of construction projects. IDU only contracts and assigns professionally qualified personnel to these supervisory functions. IDU also requires that contractors hire professionally qualified environmental and social coordinators for all construction projects. The contracts between IDU and the construction companies stipulates that contractors must provide the necessary induction and on-going training to all of its workers that include environmental and health/safety aspects from IDU’s guidelines as well as any actions approved within the PIPMA.
Although the most significant environmental and social impacts occur in the construction activities under IDU’s jurisdiction, IDU has also prepared an Institutional Environmental Management Plan (PIGA), as required by local regulations. Since early 2007, IDU has began to implement a series of internal environmental initiatives intended to increase the environmental conscience of its own staff across all departments and estimate the footprint of its own operations with regards to energy consumption, water consumption, waste generation, and wastewater discharges from its 1,400 employees located in various office buildings in Bogota.
- Monitoring:
During the project implementation phase, the work of all contractors is supervised and monitored by an independent contractor overseer (Interventor) who reports directly to IDU on the construction contractor’s compliance with contract and legal requirements. The independent overseer conducts daily inspections and prepares weekly reports following a set of checklists and report formats applicable to environmental, occupational health and safety, and community safety issues. Environmental monitoring includes such aspects as the accumulation, storage and disposal of construction site and demolition waste, stormwater runoff controls, and fuel spill prevention. Worker health and safety monitoring checklists cover such aspects as the use of personal protective equipment. Community safety monitoring checklists cover numerous areas including the installation and maintenance of traffic and pedestrian safety signage and barriers and the condition and safety of machinery, while social aspects include the staffing and management of the public information centers and the timeliness and effectiveness of complaints raised through the community-based committees.
The independent contractor overseer reports to IDU on the project monitoring results on a weekly basis. The results are compiled monthly and used to score of the contractor’s compliance with environmental, health, safety, and social requirements based on a methodology developed by IDU. The score generated as a result of the contractor performance is tied to a financial incentive included in all construction contracts. The cost of implementation of the environmental, health, safety, and social requirements of each project is included in the budget and contract of each project. Scores with less than 100% compliance result in a reduction in payment to the contractor according to the contract terms. Approximately 1.5% to 2% of the total project contract values are typically tied to performance on implementation of the environmental and social action plans.
Since early 2007, IDU has also started to track energy consumption, water consumption, waste generation, and wastewater discharges from its 1,400 employees located in various office buildings in Bogota. This information will be included in by-annual Institutional Environmental Management Plan (PIGA) reports to be issued to the District’s Environmental Secretariat.
- Reporting:
On construction projects, independent contractor overseers submit monthly and project completion reports to IDU. The reports evaluate contractors’ compliance with legal requirements and adherence to mitigation measures outlined in the environmental management plan’s implementation program. The reports are submitted to IDU’s senior management. Every three years, IDU publishes an institutional Management Program which summarizes the institution’s performance against its strategic objectives as well as a series of key performance indicators among which are included several metrics for community engagement programs. The most recent publication of the Management Program is available on the institution’s website at: http://www.idu.gov.co/entidad/informes_gestion.asp.
- Labor Issues
- Working Conditions and Management of Worker Relationships:
IDU employs approximately 1,400 persons directly while the number of workers employed through contractors varies depending on the number of projects under execution at a particular point in time but may range from 2,000 to 4,000. IDU’s direct employees are all designated as “public employees” and their labor rights are clearly defined under national and district level laws, decrees and resolutions applicable to the civil service. IDU’s human resources policy is consistent with national legal requirements applicable to the civil service which clearly define workers rights related to wages and benefits. The induction program applied to all employees within the decentralized public entities of the Bogota Capital District, including IDU, provides clear information about these legal rights in the form of presentations and pamphlets.
In accordance with National Law, IDU recognizes, and does not interfere, with their workers’ rights to form and to join workers’ organizations of their choosing and to bargain collectively. Labor unions with the greatest level of representation among District employees in Bogota include the Central Unitaria de Trabajadores (CUT), Confederación de Trabajadores de Colombia (CTC), Confederación General del Trabajo (CGT), Federación Nacional de trabajadores del Estado (FENALTRASE), and Unión Nacional de Empleados y Trabajadores Estatales (UNETE). The most recent collective agreement reached between the Capital District of Bogota and the aforementioned labor unions was reached on May 2, 2007, and covers five principal areas which include:
- salaries;
- administrative careers, training, job security, benefits and incentives;
- union rights and guarantees;
- employment conditions and guarantees; and
- occupational health.
Recently enacted regulations in Colombia have created a highly transparent employee selection process applicable to all civil service positions within the Capital District. The new program minimizes or nearly eliminates the possibility of discrimination during the hiring process. Based on a process created and managed by the National Commission for Civil Service, all civil service vacancies are now advertised at the national level. Applicants are required to take qualifying exams before they can be shortlisted for interviews. Interviews are conducted by a central commission where qualified candidates are finally ranked based on a total score resulting for a combination of educational level and experience. The offer is made to the employee with the highest score. Except for defining the description of the position to be posted, direct employers within public institutions are completely excluded from the selection process, even from the interview process.
Civil service employees are afforded a grievance mechanism and process also as defined by national law (Ley de Acoso Laboral). National legislation includes requirements for the confidential treatment of grievances and the resolution of conflicts through joint management and employee committees. The law further defines conciliation as well as disciplinary processes applicable to all levels of civil service employees from administrative to senior management.
IDU seeks to maximize the employment of residents of low-income communities near its projects through a program primarily oriented toward non-skilled workers. Certain requirements are placed on the construction contracts and IDU additionally facilitates the training of workers selected through this program.
- Occupational Health and Safety:
IDU’s occupational health and safety program is primarily focused on the employees of the construction contractors who are exposed to most significant occupational health and safety hazards. IDU’s Environmental Guidelines include a set of operating objectives based on the identification and quantification of workplace risks coupled with applicable legal and other requirements. To prevent workplace accidents and promote the health of its employees, IDU further has a set of documented procedures which address the continuous identification of dangerous conditions, evaluation of associated risks, and implementation of control measures. IDU requires that contractors train employees in understanding workplace risks and their prevention and control, including the use of personal protective equipment (PPE), hazardous materials handling, and emergency response. Activities are routinely monitored, inspected, and audited by the independent contractor overseer. Incidents and accidents are investigated according to a documented procedure so that steps can be taken to prevent reoccurrence.
- Emissions, Effluents and Waste:
IDU requires all its construction contractors to practice effective pollution prevention and abatement during construction activities where the most significant environmental impacts occur according to the technical specifications outlined in IDU’s environmental guidelines and as defined specifically for each project in the implementation program for the environmental management plan (PIPMA). Key issues managed during construction surround mitigating impacts associated with road construction and rehabilitation – that is, controlling dust and noise, protection of the quality of water and soil resources through sediment and erosion control, controlling sanitary effluents from construction camps, managing the storage and disposal of construction and demolition debris, and managing hazardous materials and other wastes such as used oil and tires generated from construction equipment maintenance.
- Community Health and Safety:
The provision of a safe and healthy environment for the community is at the core of IDU’s objectives and is incorporated into every project’s conceptual design, especially with regard to public use areas such as sidewalks, pedestrian overpasses, and bicycle routes, all of which are key components of IDU’s infrastructure development strategy. IDU also requires construction contractors to implement public safety measures in all construction projects according to the technical specifications outlined in IDU’s environmental guidelines and as defined specifically for each project in the implementation program for the environmental management plan (PIPMA). Key issues managed during construction surround mitigating impacts associated with road construction and rehabilitation – that is, providing safety signage and barriers to orient and separate vehicles and pedestrians, providing safe temporary walkways and road crossings for pedestrians, educating the affected community about the hazards associated with construction projects and in the importance of maintaining the integrity of safety devices, operating construction equipment in a safe manner and providing preventive maintenance to prevent mechanical malfunction, preparing for emergency situations.
- Land Acquisition and Involuntary Resettlement
- Compensation and Benefits for Displaced Persons:
IDU’s initial approach during every project design is to avoid displacement. Where displacement can not be avoided, IDU’s policy is to acquire properties or establish right-of-ways through direct negotiations with the landowners. IDU applies its acquisition and resettlement procedure following completion of project studies and design and after the project has been approved by the Capital District Planning office. IDU then makes offers to the landowners based on the market value of the land following title verification, a property survey, and a commercial / reference valuation. The valuations provided to landowners are performed by registered contractors and include an explanation of the reasons for the assessed value. IDU resorts to judicial expropriation only in cases where it is not possible to reach an agreement with the landowner.
- Consultation and Grievance Mechanism:
IDU maintains continuous communications with local communities about matters that concern them, including land acquisition. IDU informs landowners, local communities and local authorities about land acquisition plans and procedures. IDU documents all land transactions and payments for damages in written agreements or contracts, the contents of which are the product of negotiations and consultations. Relocation plans are based on consultations and agreements with displaced persons and communities. IDU has a system to address concerns of persons or communities affected by company activities in a systematic and prompt manner.
- Resettlement Planning and Implementation:
As a first step in resettlement planning, IDU conducts a census with appropriate socio-economic baseline data to identify the persons who will be displaced by the project and to determine who will be eligible for compensation and assistance. To discourage inflow of people who are ineligible for these benefits, IDU places a 1-year minimum tenure period for eligibility.
IDU has significant experience in resettlement preparation, implementation, and monitoring. IDU prepares Resettlement Action Plans (RAPs) in all cases where people will be affected by land acquisition, loss of property or loss of access to economic resources. IDU also provides compensation in the form of land, housing and assistance (legal, moral, training etc), depending on the evaluated impact. For projects previously financed by the World Bank, IDU has prepared RAPs that include information on the following:
- continuous information/consultation/participation campaign,
- demographic and socio-economic data on population in the project areas;
- database for management of resettlement data;
- the institutional and organizational arrangements and the legal framework,
- eligibility criteria and compensation categories, valuations of land, buildings, and all other property;
- implementation of different income restoration activities;
- individual/household/community compensation agreements;
- organization of evaluations, selling/buying procedures, actual moves and transfers;
- attention and additional assistance to vulnerable households;
- restoration of required public utility services;
- recognition and assistance with obtaining all land/property documents;
- legal assistance to project affected people and to serve as legal council;
- interact with and preparation of assistance to host communities;
- establishment of information offices and management of complaints and grievances;
- management of internal monitoring and evaluation processes; and
- management of allocated budget in close synchronization with the implementation schedule, in particular coordination with civil works.
- Physical Displacement:
Prior to establishing the land ownership rights of potentially resettled persons, IDU conducts a 20-year title record search. IDU offers displaced persons who are land owners choices among feasible resettlement options, including adequate replacement housing or financial compensation as well as relocation assistance prior to relocation. IDU provides legal assistance to those who live on untitled land and do not pay rent to obtain legal title so they can also be compensated as land owners. To all others, including renters, IDU offers a series of social services and assistance to help them find a suitable alternative that takes into account the needs of the social unit.
- Economic Displacement:
Because up to 70% of social units in areas affected by resettlement form part of the informal sector, IDU provides substantial assistance to help them restore their livelihood taking into account their land ownership status and the nature of the economic activity. The types of assistance offered by IDU, in association with other public entities and NGOs, include training and facilitation of access to credit facilities. Because a large proportion of physically and economically displaced households are headed by women, IDU provides specific training and assistance programs focusing on women’s needs.
- Biodiversity Conservation
IDU actively addresses the significance of the impact of transport infrastructure construction projects on the primarily urban ecosystems in which project development takes place, principally due to already limited availability of natural vegetation in the urban context and its value as a landscape enhancing feature and as a habitat to native or migrating bird species. Although IDU’s construction activities are confined to modified habitat, IDU’s environmental management guidelines still require contractors to conduct a survey of forest resources before commencement of construction activities and prepare a vegetation management program following the technical specifications outlined in IDU’s environmental guidelines, as defined specifically for each project in the environmental management plan (PIPMA). The main objective of the vegetation management program in construction projects is to achieve no net loss of trees in the urban setting, attaining an increase in vegetation density whenever feasible. For example, the guidelines require the replacement of each tree removed with five trees of native species, taking into account space limitations. Contractors are also required to provide maintenance to newly vegetated areas during the initial period of reinstatement. IDU‘s activities currently do not take place in critical habitats or legally protected areas.
- Cultural Heritage
IDU’s environmental management guidelines include a requirement which calls for the suspension of construction activities in the event of a chance find of archeological artifacts. The guideline includes a procedure requiring the continuous guarding of the area to prevent theft and immediately contacting competent authorities, such as Colombian Institute of Anthropology and History and the Environmental Secretariat, until a time that these authorities can assess the find and implement a plan for its recovery.
- Environmental and Social Assessment:
In the development of all new projects, IDU undertakes an environmental and social assessment of the aspects and impacts, both negative and positive, in the project’s zone of influence. The environmental and social assessment cycle begins at the earliest stage of the project planning effort, that is, during field surveys and pre-feasibility studies, where technically and financially feasible alternatives are examined. This process considers all potential impacts and applicable legal requirements of the various authorities with jurisdiction over social and environmental matters in the City of Bogota. Depending on the nature of the infrastructure development activities undertaken by IDU, additional authorities with jurisdiction over these projects may include various dependencies of the Greater Municipality of Bogota (Alcaldia Mayor) such as the Capital District’s Environmental Secretariat and various other public service corporations (i.e. Water and Sewer Service). The environmental assessments are typically the responsibility of contractors who must ensure that the assessment meet regulatory requirements to obtain the necessary environmental permits from the Environmental Secretariat. The social assessments involving land acquisition and involuntary resettlement include detailed socio-economic surveys and census which are normally conducted by personnel from IDU’s social management department and, depending on the size and complexity of the project, with the assistance of external contracted experts.
- Management Program:
Responsible environmental and social performance is embedded within the IDU’s mission, vision, and urban development strategy. IDU has established a robust environmental and social management program that aims to incorporate a series of functional elements and tools into the implementation of its environmental and social policy during the design, construction and maintenance of urban transport infrastructure. The elements of this program include clearly articulated objectives, strategies, assignment of responsibilities, supervision and audit programs, and a feedback mechanism for the review of environmental and social policies.
Comprising five key objectives, IDU’s written Environmental Policy aims to protect the environment through the rational use of renewable natural resources and through protection of worker and community health and safety by targeting the following objectives: incorporating environmental considerations as early as possible in the project planning phase and throughout the project life cycle; fostering an individual and collective change in the environmental conscience and commitment for compliance with environmental laws of managers, employees and contractors; collaborating with the monitoring work of the independent contractor oversight process (Interventoria); and achieving institutional and inter-institutional coordination.
Based on the results of the environmental and social impact assessments, IDU prepares the respective, project-specific management plans. Implementation of social management plans entailing land acquisition and resettlement are implemented by IDU, with the assistance of other government entities that provide complementary social services. Responsibility for the preparation of the implementation program for the environmental management plan (PIPMA) is assigned to the contractors responsible for the works according to the requirements of IDU’s environmental and social action programs and associated guidelines. The PIPMA specifies mitigation measures for various potential adverse impacts in the pre-construction, construction and operation phases of the project.
IDU has a complete package of guidelines and mandatory procedures to ensure proper environmental design, management and monitoring of infrastructure Works. Specifically, IDU has the following guidelines:
- Guidelines for Environmental Management of small and mid-size Infrastructure Works;
- Environmental Guidelines for Infrastructure Projects Design;
- Complement to Bogotá’s Green Manual, to ensure proper management of forest specimens;
- Guidelines for Occupational Health and Industrial Safety;
- Manual for Environmental Monitoring of Works; and
- Environmental Management Assessment and checklists.
The guidelines include programs for:
- camp site management;
- management of borrow materials and sites;
- management of wastes and disposal;
- traffic management;
- public participation;
- management of green areas;
- risk and occupational health and safety;
- management of drainage, pavements and concrete structures;
- management of chemicals, liquid waste, oils, and fuels;
- water management;
- management of equipment and machinery; and
- control of emissions and noise.
IDU has also recently developed a series of environmental, health, and safety guidelines specifically applicable to construction of road infrastructure in rural areas around the Capital. The rural guidelines include sections specifically designed for application of specific geographic areas and a matrix that can be used to determine the applicable of certain sections of the guidelines.
Although the most significant environmental and social impacts occur in the construction activities under IDU’s jurisdiction, IDU has also prepared an Institutional Environmental Management Plan (PIGA), as required by local regulations. Since early 2007, IDU has began to implement a series of internal environmental initiatives intended to increase the environmental conscience of its own staff across all departments and define and estimate the footprint of its own operations with regards to energy consumption, water consumption, waste generation, and wastewater discharges from its 1,400 employees located in various office buildings in Bogota.
IDU is targeting to complete the certification of its corporate environmental management system under the ISO 14,000 requirements by the end of 2007.
IDU has a social management program that addresses land acquisition and resettlement activities as well as community issues during the implementation of construction activities. The land acquisition and resettlement program has a combination of social ad economic components with the objective of obtaining comparable or improved conditions for resettled persons. The social component of the program includes a series of complementary processes and activities designed to provide social support associated with the design and implementation of resettlement plans including a social support process which provides potentially displaced individuals and families with a permanent source of information and operational support throughout resettlement activities (i.e. access to needed social services such as health, education, nutrition, supplemental income for families led by women, and special attention to vulnerable individuals, etc); real estate advice and search assistance; legal advice and assistance; and economic advice. The economic component of the social management program is designed in accordance with national and municipal compensation laws and IDU’s internal administrative requirements which determine the appropriateness of the financial compensation and which provides guidance on its effective use, especially in cases of economic displacement.
- Organization:
IDU has institutionalized its environmental guidelines and social action policies and has environmental and social management departments staffed with qualified specialists that have experience in managing the environmental and social impacts of its projects. Overall responsibility and authority for implementation of IDU’s environmental and social policies and programs lies with corporate environmental and social departments which provide a direct advisory service to the General Director’s office. Implementation of environmental and social programs is further supported by various departments within the Corporate Sub-Directorate, which is responsible for IDU’s internal administrative functions, and the Technical Sub-Directorate, which is responsible for various project implementation areas such as:
- project studies and design;
- land acquisition; and
- construction management.
The environmental and social departments are each led by their respective managers and staffed by interdisciplinary teams of specialists which include engineers, planners, lawyers, sociologist, and anthropologists.
Compliance of contractor’s implementation of the PIPMAs is ensured through the bidding documents and legal contracts which include and financial incentives. Contractors are required to have resident environmental and social supervisors and vegetation management specialists whose appointments for the specific project must be approved by IDU based on a series of minimum qualifications also outlined in the contract. Project implementation is continually supervised and audited by independent construction supervisors who conduct daily inspections used to create weekly scores of performance on the environmental and social contract requirements of the project. Weekly compliance scores are averaged on a monthly basis and then used to adjust the payment of a portion of the contract set aside as a budget for the implementation of environmental and social management plans. IDU, the contractor, and the independent project supervisors meet on a weekly to monthly basis to discuss the results of the evaluation and to modify the implementation program if required to address identified problems.
- Training:
IDU primarily has a supervisory and oversight role in the implementation of construction projects. IDU only contracts and assigns professionally qualified personnel to these supervisory functions. IDU also requires that contractors hire professionally qualified environmental and social coordinators for all construction projects. The contracts between IDU and the construction companies stipulates that contractors must provide the necessary induction and on-going training to all of its workers that include environmental and health/safety aspects from IDU’s guidelines as well as any actions approved within the PIPMA.
Although the most significant environmental and social impacts occur in the construction activities under IDU’s jurisdiction, IDU has also prepared an Institutional Environmental Management Plan (PIGA), as required by local regulations. Since early 2007, IDU has began to implement a series of internal environmental initiatives intended to increase the environmental conscience of its own staff across all departments and estimate the footprint of its own operations with regards to energy consumption, water consumption, waste generation, and wastewater discharges from its 1,400 employees located in various office buildings in Bogota.
- Monitoring:
During the project implementation phase, the work of all contractors is supervised and monitored by an independent contractor overseer (Interventor) who reports directly to IDU on the construction contractor’s compliance with contract and legal requirements. The independent overseer conducts daily inspections and prepares weekly reports following a set of checklists and report formats applicable to environmental, occupational health and safety, and community safety issues. Environmental monitoring includes such aspects as the accumulation, storage and disposal of construction site and demolition waste, stormwater runoff controls, and fuel spill prevention. Worker health and safety monitoring checklists cover such aspects as the use of personal protective equipment. Community safety monitoring checklists cover numerous areas including the installation and maintenance of traffic and pedestrian safety signage and barriers and the condition and safety of machinery, while social aspects include the staffing and management of the public information centers and the timeliness and effectiveness of complaints raised through the community-based committees.
The independent contractor overseer reports to IDU on the project monitoring results on a weekly basis. The results are compiled monthly and used to score of the contractor’s compliance with environmental, health, safety, and social requirements based on a methodology developed by IDU. The score generated as a result of the contractor performance is tied to a financial incentive included in all construction contracts. The cost of implementation of the environmental, health, safety, and social requirements of each project is included in the budget and contract of each project. Scores with less than 100% compliance result in a reduction in payment to the contractor according to the contract terms. Approximately 1.5% to 2% of the total project contract values are typically tied to performance on implementation of the environmental and social action plans.
Since early 2007, IDU has also started to track energy consumption, water consumption, waste generation, and wastewater discharges from its 1,400 employees located in various office buildings in Bogota. This information will be included in by-annual Institutional Environmental Management Plan (PIGA) reports to be issued to the District’s Environmental Secretariat.
- Reporting:
On construction projects, independent contractor overseers submit monthly and project completion reports to IDU. The reports evaluate contractors’ compliance with legal requirements and adherence to mitigation measures outlined in the environmental management plan’s implementation program. The reports are submitted to IDU’s senior management. Every three years, IDU publishes an institutional Management Program which summarizes the institution’s performance against its strategic objectives as well as a series of key performance indicators among which are included several metrics for community engagement programs. The most recent publication of the Management Program is available on the institution’s website at: http://www.idu.gov.co/entidad/informes_gestion.asp.
- Labor Issues
- Working Conditions and Management of Worker Relationships:
IDU employs approximately 1,400 persons directly while the number of workers employed through contractors varies depending on the number of projects under execution at a particular point in time but may range from 2,000 to 4,000. IDU’s direct employees are all designated as “public employees” and their labor rights are clearly defined under national and district level laws, decrees and resolutions applicable to the civil service. IDU’s human resources policy is consistent with national legal requirements applicable to the civil service which clearly define workers rights related to wages and benefits. The induction program applied to all employees within the decentralized public entities of the Bogota Capital District, including IDU, provides clear information about these legal rights in the form of presentations and pamphlets.
In accordance with National Law, IDU recognizes, and does not interfere, with their workers’ rights to form and to join workers’ organizations of their choosing and to bargain collectively. Labor unions with the greatest level of representation among District employees in Bogota include the Central Unitaria de Trabajadores (CUT), Confederación de Trabajadores de Colombia (CTC), Confederación General del Trabajo (CGT), Federación Nacional de trabajadores del Estado (FENALTRASE), and Unión Nacional de Empleados y Trabajadores Estatales (UNETE). The most recent collective agreement reached between the Capital District of Bogota and the aforementioned labor unions was reached on May 2, 2007, and covers five principal areas which include:
- salaries;
- administrative careers, training, job security, benefits and incentives;
- union rights and guarantees;
- employment conditions and guarantees; and
- occupational health.
Recently enacted regulations in Colombia have created a highly transparent employee selection process applicable to all civil service positions within the Capital District. The new program minimizes or nearly eliminates the possibility of discrimination during the hiring process. Based on a process created and managed by the National Commission for Civil Service, all civil service vacancies are now advertised at the national level. Applicants are required to take qualifying exams before they can be shortlisted for interviews. Interviews are conducted by a central commission where qualified candidates are finally ranked based on a total score resulting for a combination of educational level and experience. The offer is made to the employee with the highest score. Except for defining the description of the position to be posted, direct employers within public institutions are completely excluded from the selection process, even from the interview process.
Civil service employees are afforded a grievance mechanism and process also as defined by national law (Ley de Acoso Laboral). National legislation includes requirements for the confidential treatment of grievances and the resolution of conflicts through joint management and employee committees. The law further defines conciliation as well as disciplinary processes applicable to all levels of civil service employees from administrative to senior management.
IDU seeks to maximize the employment of residents of low-income communities near its projects through a program primarily oriented toward non-skilled workers. Certain requirements are placed on the construction contracts and IDU additionally facilitates the training of workers selected through this program.
- Occupational Health and Safety:
IDU’s occupational health and safety program is primarily focused on the employees of the construction contractors who are exposed to most significant occupational health and safety hazards. IDU’s Environmental Guidelines include a set of operating objectives based on the identification and quantification of workplace risks coupled with applicable legal and other requirements. To prevent workplace accidents and promote the health of its employees, IDU further has a set of documented procedures which address the continuous identification of dangerous conditions, evaluation of associated risks, and implementation of control measures. IDU requires that contractors train employees in understanding workplace risks and their prevention and control, including the use of personal protective equipment (PPE), hazardous materials handling, and emergency response. Activities are routinely monitored, inspected, and audited by the independent contractor overseer. Incidents and accidents are investigated according to a documented procedure so that steps can be taken to prevent reoccurrence.
- Emissions, Effluents and Waste:
IDU requires all its construction contractors to practice effective pollution prevention and abatement during construction activities where the most significant environmental impacts occur according to the technical specifications outlined in IDU’s environmental guidelines and as defined specifically for each project in the implementation program for the environmental management plan (PIPMA). Key issues managed during construction surround mitigating impacts associated with road construction and rehabilitation – that is, controlling dust and noise, protection of the quality of water and soil resources through sediment and erosion control, controlling sanitary effluents from construction camps, managing the storage and disposal of construction and demolition debris, and managing hazardous materials and other wastes such as used oil and tires generated from construction equipment maintenance.
- Community Health and Safety:
The provision of a safe and healthy environment for the community is at the core of IDU’s objectives and is incorporated into every project’s conceptual design, especially with regard to public use areas such as sidewalks, pedestrian overpasses, and bicycle routes, all of which are key components of IDU’s infrastructure development strategy. IDU also requires construction contractors to implement public safety measures in all construction projects according to the technical specifications outlined in IDU’s environmental guidelines and as defined specifically for each project in the implementation program for the environmental management plan (PIPMA). Key issues managed during construction surround mitigating impacts associated with road construction and rehabilitation – that is, providing safety signage and barriers to orient and separate vehicles and pedestrians, providing safe temporary walkways and road crossings for pedestrians, educating the affected community about the hazards associated with construction projects and in the importance of maintaining the integrity of safety devices, operating construction equipment in a safe manner and providing preventive maintenance to prevent mechanical malfunction, preparing for emergency situations.
- Land Acquisition and Involuntary Resettlement
- Compensation and Benefits for Displaced Persons:
IDU’s initial approach during every project design is to avoid displacement. Where displacement can not be avoided, IDU’s policy is to acquire properties or establish right-of-ways through direct negotiations with the landowners. IDU applies its acquisition and resettlement procedure following completion of project studies and design and after the project has been approved by the Capital District Planning office. IDU then makes offers to the landowners based on the market value of the land following title verification, a property survey, and a commercial / reference valuation. The valuations provided to landowners are performed by registered contractors and include an explanation of the reasons for the assessed value. IDU resorts to judicial expropriation only in cases where it is not possible to reach an agreement with the landowner.
- Consultation and Grievance Mechanism:
IDU maintains continuous communications with local communities about matters that concern them, including land acquisition. IDU informs landowners, local communities and local authorities about land acquisition plans and procedures. IDU documents all land transactions and payments for damages in written agreements or contracts, the contents of which are the product of negotiations and consultations. Relocation plans are based on consultations and agreements with displaced persons and communities. IDU has a system to address concerns of persons or communities affected by company activities in a systematic and prompt manner.
- Resettlement Planning and Implementation:
As a first step in resettlement planning, IDU conducts a census with appropriate socio-economic baseline data to identify the persons who will be displaced by the project and to determine who will be eligible for compensation and assistance. To discourage inflow of people who are ineligible for these benefits, IDU places a 1-year minimum tenure period for eligibility.
IDU has significant experience in resettlement preparation, implementation, and monitoring. IDU prepares Resettlement Action Plans (RAPs) in all cases where people will be affected by land acquisition, loss of property or loss of access to economic resources. IDU also provides compensation in the form of land, housing and assistance (legal, moral, training etc), depending on the evaluated impact. For projects previously financed by the World Bank, IDU has prepared RAPs that include information on the following:
- continuous information/consultation/participation campaign,
- demographic and socio-economic data on population in the project areas;
- database for management of resettlement data;
- the institutional and organizational arrangements and the legal framework,
- eligibility criteria and compensation categories, valuations of land, buildings, and all other property;
- implementation of different income restoration activities;
- individual/household/community compensation agreements;
- organization of evaluations, selling/buying procedures, actual moves and transfers;
- attention and additional assistance to vulnerable households;
- restoration of required public utility services;
- recognition and assistance with obtaining all land/property documents;
- legal assistance to project affected people and to serve as legal council;
- interact with and preparation of assistance to host communities;
- establishment of information offices and management of complaints and grievances;
- management of internal monitoring and evaluation processes; and
- management of allocated budget in close synchronization with the implementation schedule, in particular coordination with civil works.
- Physical Displacement:
Prior to establishing the land ownership rights of potentially resettled persons, IDU conducts a 20-year title record search. IDU offers displaced persons who are land owners choices among feasible resettlement options, including adequate replacement housing or financial compensation as well as relocation assistance prior to relocation. IDU provides legal assistance to those who live on untitled land and do not pay rent to obtain legal title so they can also be compensated as land owners. To all others, including renters, IDU offers a series of social services and assistance to help them find a suitable alternative that takes into account the needs of the social unit.
- Economic Displacement:
Because up to 70% of social units in areas affected by resettlement form part of the informal sector, IDU provides substantial assistance to help them restore their livelihood taking into account their land ownership status and the nature of the economic activity. The types of assistance offered by IDU, in association with other public entities and NGOs, include training and facilitation of access to credit facilities. Because a large proportion of physically and economically displaced households are headed by women, IDU provides specific training and assistance programs focusing on women’s needs.
- Biodiversity Conservation
IDU actively addresses the significance of the impact of transport infrastructure construction projects on the primarily urban ecosystems in which project development takes place, principally due to already limited availability of natural vegetation in the urban context and its value as a landscape enhancing feature and as a habitat to native or migrating bird species. Although IDU’s construction activities are confined to modified habitat, IDU’s environmental management guidelines still require contractors to conduct a survey of forest resources before commencement of construction activities and prepare a vegetation management program following the technical specifications outlined in IDU’s environmental guidelines, as defined specifically for each project in the environmental management plan (PIPMA). The main objective of the vegetation management program in construction projects is to achieve no net loss of trees in the urban setting, attaining an increase in vegetation density whenever feasible. For example, the guidelines require the replacement of each tree removed with five trees of native species, taking into account space limitations. Contractors are also required to provide maintenance to newly vegetated areas during the initial period of reinstatement. IDU‘s activities currently do not take place in critical habitats or legally protected areas.
- Cultural Heritage
IDU’s environmental management guidelines include a requirement which calls for the suspension of construction activities in the event of a chance find of archeological artifacts. The guideline includes a procedure requiring the continuous guarding of the area to prevent theft and immediately contacting competent authorities, such as Colombian Institute of Anthropology and History and the Environmental Secretariat, until a time that these authorities can assess the find and implement a plan for its recovery.
Stakeholder Engagement
As a public service institution devoted to the development and improvement of transport infrastructure, IDU is a highly publicly visible organism within the Bogota Capital District. IDU has a well organized community outreach program as part of the social management program which promotes public participation throughout the project cycle beginning with community information meetings and the creation of community project oversight committees in coordination with community leaders, organization representatives, residents, and businesspeople. IDU provides training to members of the community oversight committees and implements campaigns of continuous information diffusion with various information methods including the installation of satellite information centers, household distribution of flyers, and placement of information signs at key locations.
During the implementation of construction activities, contractors are required to install community information centers at the construction site (Centros de Reunion, Encuentro, y Atencion en obra - CREA). The CREAs are offices whose location can be easily identified by community members (through signs with directions although they are also advertised through the IDU’s website at:
http://www.idu.gov.co/servicios/puntos_crea.asp
They are staffed by a qualified social worker during project working hours and provide a collection of readily available project information including visual aids, plans, and other information of interest to the community. Each project must also form a CREA Committee constituted by community leaders and residents of the project area of influence who meet with the contractor, the independent contractor overseer, and IDU to identify project progress, problems, and their alternatives for resolution. Additionally, the CREA Committees conduct educational campaigns in community organizations and local schools. IDU also maintains an office dedicated to the attention of public inquiries and complaints through a widely publicized phone number through a web portal at:
http://www.idu.gov.co/servicios/linea_atencion.asp
IDU maintains an exhaustive list of the projects under construction with maps, timelines, and information about the contractor also posted on the website at:
http://www.idu.gov.co/sist_vial/obras_en_ejecucion.htm
This information is complemented by a well established public relations campaign to promote announcements in the radio and press about road closures, traffic delays, or other issues of public concern associated with road infrastructure construction activities.
For inquiries and comments about the project, please contact:
Rigoberto Lugo, Director de Crédito Público
Cra. 30 No. 24-90 Piso 2, Bogota
Telephone: +57-1-338-5356
Fax: +57-1-338-5360
During the implementation of construction activities, contractors are required to install community information centers at the construction site (Centros de Reunion, Encuentro, y Atencion en obra - CREA). The CREAs are offices whose location can be easily identified by community members (through signs with directions although they are also advertised through the IDU’s website at:
http://www.idu.gov.co/servicios/puntos_crea.asp
They are staffed by a qualified social worker during project working hours and provide a collection of readily available project information including visual aids, plans, and other information of interest to the community. Each project must also form a CREA Committee constituted by community leaders and residents of the project area of influence who meet with the contractor, the independent contractor overseer, and IDU to identify project progress, problems, and their alternatives for resolution. Additionally, the CREA Committees conduct educational campaigns in community organizations and local schools. IDU also maintains an office dedicated to the attention of public inquiries and complaints through a widely publicized phone number through a web portal at:
http://www.idu.gov.co/servicios/linea_atencion.asp
IDU maintains an exhaustive list of the projects under construction with maps, timelines, and information about the contractor also posted on the website at:
http://www.idu.gov.co/sist_vial/obras_en_ejecucion.htm
This information is complemented by a well established public relations campaign to promote announcements in the radio and press about road closures, traffic delays, or other issues of public concern associated with road infrastructure construction activities.
For inquiries and comments about the project, please contact:
Rigoberto Lugo, Director de Crédito Público
Cra. 30 No. 24-90 Piso 2, Bogota
Telephone: +57-1-338-5356
Fax: +57-1-338-5360
Press-Release
Related SII
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**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.