ame:
Elin Wrzoncki
Organisation:
Danish Institute for Human Rights
Response:
COMMENTS TO RENEWED DANISH SUPPORT TO THE WORLD BANK ENERGY SECTOR MANAGEMENT ASSISTANCE PROGRAM (ESMAP), 2025-2030 The Danish Institute for Human Rights welcomes the Danish Support for the Energy Sector Management Assistance Program (ESMAP) with a view to ensuring universal access to affordable, reliable, and modern energy services by 2030, accelerating the transition towards a sustainable, just and net zero energy system; and ensuring the resilience of the energy sector to adapt to impacts of climate change. While energy access is critical to the realisation of many human rights such as the right to health, the right to a clean and healthy environment, the right to education etc., energy generation and transmission projects may also have adverse human rights impacts. Therefore, the focus on the principles of a human rights-based approach (articulated as PANT) are welcome, however it is suggested human rights risks could also be identified more clearly in the Programme and human rights mainstreamed into the Programme. In relation to Electricity Access Program in Sub-Saharan Africa in particular, special attention needs to be given to impacts of energy production and transmission on indigenous and pastoralist communities. More specifically, recognition of their rights, including to Free Prior and Informed Consent (FPIC), recognition of their territorial and cultural rights, and to an adequate and fair compensation in cases of economic and physical displacement should be articulated. A large proportion of renewable energy resources, such as wind and geothermal, are located in territories inhabited by indigenous peoples, traditional and pastoralist groups that are strongly depended on the resources and are the most affected by climate change. Also, it is important to request special attention on access to energy to precisely these groups, and the intersectional challenges of indigenous and pastoralists women and girls when designing access to energy and clean cooking programs. It is also strongly recommended to strengthen and upgrade the grievance mechanisms of the projects and programs supported by ESMAP and the WBG in order to ensure that access to remediation and justice is accessible to those persons and groups impacted. A timely identification of unintended negative impacts and inequalities can prevent the escalation of conflict and avoidable harm to local communities. Also, it is important that such redress mechanisms are gender responsive and culturally adequate. EMF could request WBG and ESMAP to consider impacts on gender and human rights of energy projects, especially in those implemented in areas of conflict, and/or characterized by extreme poverty and the presence of indigenous, traditional and pastoralist groups.
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Name:
Anders Reimers Larsen
Organisation:
CISU - Civil Society in Development
Response:
Please see attach for the inputs from CISU - Civil Society in Development, representing 290+ civil society organisations working in partnerships globally with several thousand CSOs.
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CISU input to Fund for responding to loss and damage.pdfName:
Nora Sina
Organisation:
Folkekirkens Nødhjælp
Response:
Folkekirkens Nødhjælp afgiver hermed høringssvar til Fund for responding to loss and damage Folkekirkens Nødhjælp er meget glad for at se, at Danmark allokerer penge til fonden for tab og skader. Vi bakker også varmt op om, at Danmark prioriterer at allokere midler nu på trods af, at fonden endnu ikke er funktionel. Det glæder os at den danske regering anerkender den politiske effekt af at allokere midler på nuværende tidspunkt, der netop er helt afgørende i denne process. Folkekirkens Nødhjælp har derudover kommentarer til udkastet. Alle midler til fonden rapporteres som 100% adaptation. Dette er formelt set korrekt, da RIO markørerne har en bred definition af klimatilpasning. Den politiske kontekst er dog anderledes, da majoriteten af stater ser tiltag, der adresserer tab og skader som en separat kategori, der ikke falder under klimatilpasning. Vi opfordrer derfor Danmark til ligeledes at introduceret en ny kategori for tab og skader. Folkekirkens Nødhjælp vil gerne foreslå at inkludere et yderligere niveau i Theory of Change, der har til formål at sikre, at også lokale aktører, kan få adgang til fondens midler. Niveauet skal altså sikre, at det ikke blot er “vunerable countries” men også “vunerable communities” tænkes ind. Dette skal imødegå problematikken omkring kontrol fra hovedstæderne overfor lokale samfund. Theory of change bør derfor inkludere en formulering som”If funding modalities are designed in a way so that they can channel support to local communities” og “then the most vulnerable communities…” Derudover bør der sikres et minimum kriterium for hvor stor en andel af midlerne, der skal implementes af lokale aktører. Det vil f.eks. være muligt at bygge videre på de eksisterende mål om lokalisering i Charter for Change. På trods af, at lån er fordelagtige, er de meget svære at bruge i relation til tab og skader. Folkekirkens Nødhjælp vil derfor anbefale at lån kun bliver brugt hvis initiativet inkluderer en markedsbaseret løsning, der kan sikre, at lånet kan betales tilbage indenfor rammerne for projektet. Hvis lånet kun skal betales tilbage af de lokale samfund, risikerer man at en gæld bygges op. Vi vil derfor foreslå at henvisninger til lån bliver taget ud af dokumentet eller formuleringen blødes op med henvisning til risici for ikke-bæredygtig gæld. En stor risiko i forbindelse med tab og skader er gentagelser. Dvs. et samfund, der er sårbart overfor oversvømmelser, risikeres at oversvømmes igen og igen. Det er derfor afgørende, at tiltag, der adresserer tab og skader altid inkluderer et element af klimatilpasning, der sikrer, at lokalsamfundet genopbygges bedre og tilpasset til de lokale klimaforandringer.
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Høringssvar Loss and Damage Fund.docxName:
Luna Pedersen
Organisation:
Global Focus and the Danish 92 Group
Response:
Please see attached for the inputs from Global Focus and the Danish 92 Group. Thank you!
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Global Focus and Danish 92 Group - response to 'Fund for Responding to loss and damage' at Programme Committee Meeting June 4 2024..pdfName:
Ina Lykke Jensen
Organisation:
Disabled People's Organisations Denmark
Response:
Resumé: Danske Handicaporganisationer (DH) ønsker hermed at afgive høringssvar til projektdokumentet for Danish Contribution to the Fund for responding to loss and damage 2024. DH noterer, at den operationelle ramme for fonden understøtter, at særligt grupper, der er sårbare overfor klimaforandringer og -katastrofer, effektivt involveres i arbejdet med at fremme og styrke de nationale tiltag til at adressere tab og skader. Samtidig noterer vi os, at mennesker med handicap ikke er nævnt noget sted i projektdokumentet. DH foreslår, at projektdokumentet præciserer, at mennesker med handicap er blandt de, der rammes hårdest af klimaforandringerne, og at repræsentative organisationer af mennesker med handicap derfor effektivt skal involveres i tiltag, der adresserer tab og skader, samt inddrages i beslutningsprocesser og som modtagere af fonden. Forslaget har til hensigt at fremme, at mennesker med handicap involveres og inkluderes i fondens tiltag, så mennesker med handicap i deres fulde diversitet ikke fortsat lades i stikken med den uforholdsmæssigt stor byrde af konsekvenserne af klimaforandringerne.
File:
DH_Høringssvar UM Contribution Loss and Damage.pdf
Name:
Kathrin Wessendorf
Organisation:
International Work Group for Indigenous Affairs
Response:
Dear Programme Committee, In the draft Danish Organisation Strategy for the World Bank 2025-2030, we note that Indigenous Peoples are not mentioned. We hope this can be addressed. The United Nations Permanent Forum on Indigenous Issues (UNPFII) is a high-level advisory body to the Economic and Social Council (ECOSOC). Established in 2000, the UNPFII provides expert advice and recommendations to the UN system and member states on Indigenous issues related to economic and social development, culture, the environment, education, health, and human rights. The Forum meets annually, bringing together representatives of Indigenous Peoples, member states, and UN agencies to discuss and advance Indigenous rights and priorities. Denmark actively engages with the UNPFII, reflecting its commitment to promoting human rights and inclusivity. This engagement is aligned with Denmark’s broader strategy within the UN system, as outlined in the policy document "Fælles om Fremtiden - en hvidbog om FN, Danmark og en verdensorden under pres" (page 29), which emphasizes the importance of including marginalized groups, specifically Indigenous Peoples, in international development efforts. The recommendations from the 2024 meeting of the United Nations Permanent Forum on Indigenous Issues (UNPFII) are particularly relevant to the Danish organisation Strategy for the World Bank 2025-2030. These recommendations emphasize the importance of making Indigenous Peoples a strategic priority throughout. Further, they call for increased dialogue and direct financing mechanisms for Indigenous Peoples, which align with the World Bank’s goals of inclusivity and sustainability. As Denmark has consistently prioritized the rights and inclusion of Indigenous Peoples within the UN system, addressing the missing reference to Indigenous Peoples in this strategy will underscore Denmark’s commitment to human rights, including the rights of Indigenous Peoples and align the document. From the UNPFII, we draw attention to the following recommendations: Recommendation 45: The Permanent Forum recommends that the World Bank strengthen platforms for dialogue with Indigenous Peoples at all levels. This will create strategic opportunities for Indigenous Peoples to voice their priorities and concerns. Additionally, the Forum calls on the World Bank to enhance and expand direct financing mechanisms for Indigenous Peoples. These should be linked to national programs, policy dialogue, and investments for sustainability across ecosystems. Recommendation 54: The Permanent Forum expresses concern about the harms and injustices caused by carbon markets and biodiversity credits on Indigenous Peoples' lands and territories. It urges the World Bank, alongside other international bodies, to demand high-integrity projects that ensure clear accountability for carbon and biodiversity impacts. Moreover, these projects should provide measured benefits for Indigenous Peoples. The Forum invites the World Bank to report on their actions concerning these issues at its 2025 session. These recommendations underscore the need for the World Bank to commit to safeguarding the rights and interests of Indigenous Peoples, particularly in the context of environmental and developmental projects. Addressing these points in the Danish Organisation Strategy will not only align with international best practices but also enhance the credibility and effectiveness of the World Bank’s initiatives. For further reference, the detailed recommendations can be found in the UN Permanent Forum’s 23rd session document available at: Webpage_Advance_Unedited-Version_UNPFII_2024_clean.pdf. We hope that the final strategy will reflect these critical concerns and integrate robust mechanisms for ensuring the protection and promotion of Indigenous Peoples' rights. Thank you for considering these recommendations. Sincerely, Kathrin Wessendorf Executive Director, International Work Group for Indigenous Affairs
File:
Organisation Strategy for the World Bank.docxName:
Sigrid Kromann Schiøler
Organisation:
Global Focus and the 92 Group
Response:
Please see attached the inputs from Global Focus and the Danish 92 Group. Thank you!
File:
Høringssvar til organisationsstrategi til Verdensbanken 2025-2030 GF 92grp.pdfName:
Elin Wrzoncki
Organisation:
Danish Institute for Human Rights
Response:
COMMENTS TO DANISH ORGANISATION STRATEGY FOR THE WORLD BANK 2025-2030 The Danish Institute for Human Rights (the Institute) welcomes the opportunity to input to Denmark´s strategy for engagement with and continued support of the World Bank Group (WBG). We take this opportunity to encourage the Danish Ministry of Foreign Affairs to prioritise the effective implementation of the Environmental and Social Framework (World Bank) and the Sustainability Framework (IFC) in its engagement strategy with the WBG. These frameworks have the objective of ensuring that WBG investments do not result in harm to people and the environment and expect both the WB and IFC and their public and private sector clients to have in place proper environmental and social risk management systems. Despite the existence of such important safeguards, allegations on inadequate implementation by the IFC of its sustainability commitments and procedures have come to light. A so-called ‘accountability crisis’ at the IFC has been underlined in recent developments such as the IFC management´s response to the Bridge International Academies case . Concerns have also been expressed regarding an insufficient commitment to remediation of harms linked to its investments as expressed in the Proposed IFC/MIGA Approach to Remedial Action. Such unintended harms and lack of accountability are casting a shadow on the much needed and called-for development impacts of multilateral development banks including the WBG and its private sector arm and is at risk of exacerbating the global trust crisis identified in the Strategy Document. These specific cases and concerns are to be placed in the broader context of a missing unequivocal commitment by the IFC to human rights and international responsible business conduct standards such as the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. These standards establish that all businesses, including multilateral development banks, have a responsibility to respect human rights. This responsibility means avoiding and addressing negative impacts on human rights, including when these impacts occur in the value chain of financial institutions. Such standards are by now a baseline responsibility expected of all responsible businesses. In an EU context, that responsibility has been enshrined in law with the adoption of the Corporate Sustainability Due Diligence Directive in May 2024 and recognised as important minimum safeguards in the EU’s Sustainable Finance Taxonomy. The Institute would therefore encourage the Danish Ministry of Foreign Affairs to include an explicit reference to the environmental and social frameworks of the WBG in its Organisation Strategy for the World Bank and to play a proactive role – via in particular its seat on the Nordic-Baltic Constituency – in ensuring that human rights and responsible business conduct standards receive the necessary attention, resources, and prioritisation at the WBG. This could among other things be integrated in the proposed priority area of ‘Private Capital Mobilisation’ as well as the Ministry’s approach to ongoing monitoring of positive and negative outcomes. The timing for such a focus in the next strategy period would be particularly fruitful given that the next strategy period overlaps with a much-anticipated revision of the IFC Performance Standards and the implementation of a pilot project on remediation by IFC. The Institute stands ready to engage in a dialogue with the Danish Ministry of Foreign Affairs on these matters. We remain at your disposal to provide more background about this consultation input.
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DIHR_Input to Danish Organisation Strategy for the World bank.docxName:
Kathrine Lodberg
Organisation:
Sex & Samfund / Danish Family Planning Association
Response:
The Danish Family Planning Association (DFPA) appreciates the opportunity to provide inputs and comments to the Danish Ministry of Foreign Affairs draft Organisation Strategy for the World Bank (WB) 2025-2030. We commend the successful efforts to make the WB prioritise climate change, the environment, renewable energy, gender equality, governance, fragile and conflict situations, disaster risk management and domestic resource mobilization. On gender equality, we welcome the draft WB’s Gender Strategy 2024 – 2030: Accelerate Gender Equality for a Sustainable, Resilient and Inclusive Future. The Gender strategy will come into force in a time where the anti-gender movement’s global influence is growing and gaining momentum in countries like United States, Uganda, Spain, and Hungary, and thereby also in decision making bodies in multilateral organisations like the UN and EU. This movement is diverse, well-funded, and organized and mobilizes support for legislation that opposes and criminalizes areas within sexual and reproductive health and rights. The anti-gender movement is growing against the backdrop of a divisive geopolitical climate in terms of the realization of human rights, as currently exemplified by the fact that 1/3 of the world’s LGBT+ population now live in states that criminalize same sex relations. In recent years, we have experienced a growing anti-rights/gender movement at the multilateral level, exemplified by an informal coalition of UN Member States that was convened during the Trump administration, and which promoted the ‘Geneva Consensus Declaration’ which posited support for “traditional family values” and opposed SRHR. This geopolitical backdrop underscores the importance of multilateral institutions, such as the World Bank, ensuring strong leadership and prioritization of gender equality and human rights within its mandate, strategy and portfolio of programming and financing. On top of that, the current poly-crisis in the world which are identified both in the Danish Organisation Strategy and by the WB, have disproportionate negative impacts on the most structurally excluded groups, including women, girls, sexual and gender minorities, and other marginalized groups. Gender equality is therefore globally under pressure despite evidence paradoxically showing that women’s participation in the economy and in decision making improves sustainability and resilience as well as economic growth, productivity, and poverty reduction. Therefore, it will be important to hold the WB accountable in comprehensively implementing the gender strategy, as it will both benefit the WB’s development purpose and the rights of structurally excluded groups. We regret to see that gender is not a stand-alone priority in the draft organisation strategy as it was during the former period, even though it is suggested that it will be a mainstreamed area of attention for the organization. However, it takes significant resources to mainstream gender comprehensively within an organization and to ensure there is an adequate internal awareness, political buy-in and response to related issues. Given this, The Danish Family Planning Association recommends that gender equality continues to be a stand-alone priority in the organization to ensure that resources continue to be invested in promoting gender equality. This will allow Denmark together with the Nordic Baltic Constituency to follow up on the implementation of the gender strategy and making sure that WB in accordance with its gender strategy impacts gender equality positively. With its gender focus and expertise Denmark can, in its engagement with the WB, play an important role in galvanising likeminded actors in overseeing the gender strategy, from ambition in to practice. Denmark can also contribute to this process through its representation in steering committees of trust funds and financial intermediary funds, including governing bodies of WB’s large climate facilities. This would also be in line with the findings of the MFA’s own evaluation of the Danish support to gender equality in Danish development cooperation 2014-2021 where it is encouraged to focus on gender equality in international work on climate change and green transitioning.
File:
Sex & Samfund input to Organisation Strategy for the World Bank 2025-2030.pdf