Accountability and transparency: key areas where the Caribbean Development Bank must improve
by Alessandro Ramazzotti & Anggita Indari
International Accountability Project (IAP), with the help of the Early Warning System, analyzed the current practices of the Caribbean Development Bank (CDB) in relation to international best standards and norms on access to information, revealing the bank’s weak performance on transparency, accountability, and inclusion. As a first indication of this, during the period when we conducted this full analysis, the list of projects on the CDB’s website disappeared without notice. There was no easily accessible information — if any at all — about the reason or the date it would be made public again. IAP shared the analysis with the CDB in December 2023, but as of publication time have not received a response.
Similar to our previous assessments of Multilateral Development Banks’ (MDBs) disclosure practices — see our previous analyses of the Dutch Entrepreneurial Development Bank (FMO), the African Development Bank, IDB Invest, and the U.S. International Development Finance Corporation (DFC) — we analyzed the information provided by the CDB on 84 projects disclosed on the bank’s website. Specifically, we used 18 criteria, based on the principle of early access to information to assess the bank’s practices on: (i) safeguards, project documents, and mitigation measures; (ii) stakeholders engagement and project consultation process; and (iii) contacts availability and continued engagement throughout the project cycle. All the elements that we took into consideration contribute to communities’ rights to inclusive, transparent, and accountable development processes, as mandated by the Declaration on the Right to Development (1986).
When it comes to transparency and accountability, the CDB figures are among the worst MDBs analyzed by IAP. Indeed, the bank seems to rarely disclose relevant documents, including those that might facilitate the involvement of project-affected stakeholders throughout the project cycle. It does not provide project-specific contact information, nor adequate information regarding its grievance mechanisms and how to access them. It needs to considerably improve on all fronts, and we hope that it will work to do so promptly.
The CDB needs to improve the accessibility of project documents and the performance of environmental and social impact assessments
One of the most consequential omissions we observed is that the CDB does not disclose information on projects’ environmental and social impacts, nor the mitigation plans for related risks. When it does — only in 2 out of the 84 (2.4% of the dataset) projects we analyzed — it is not on the project disclosure website and is found only in project documents, which diminishes accessibility by project-affected communities. Because of this, communities in project areas may face more difficulty in understanding project impacts and specific locations, and find themselves unable to provide inputs throughout project phases.
We identified limited accessibility to project documents, as many were not attached to the designated disclosure page. Moreover, despite the bank’s regional focus, we did not find a single project document provided in a language other than English. This prejudices the right to access information of all those people living in the multicultural Caribbean region — including Indigenous communities — who speak French, Haitian, Creole, Papiamentu, as well as other languages and dialects.
Apart from constituting a breach of people’s right to access information, the failure to disclose project-related documentation compromises the affected people’s readiness to respond to damages and adverse impacts. This might potentially threaten the livelihoods of project-affected people in case of substantial environmental and social impacts, also considering that the CDB does not disclose the project risk category, an essential piece of information to understand the potential impacts of a project.
The disclosure of such documents acquires additional importance in the Caribbean context, where many projects — on the basis of the sample of 84 that we analyzed — finance infrastructure improvements and construction of energy, and education and health facilities; activities with potentially adverse social and environmental impacts. Moreover, considering the numerous (12 out of 84, that is 14.3% of the dataset) projects addressing humanitarian crises, disclosing project-related information could support disaster-affected people to recover faster and with a more participated — and therefore resilient — approach to disaster responses.
Last but not least, using the bank’s website as the only way of providing information does not take into account the regional context, where many people — especially in the marginalized communities who are usually most affected by development projects — do not have a stable and reliable connection to the Internet. The CDB must ensure that project-related information, above all that on potential adverse impacts and mitigation measures, reaches communities in a timely manner, so as to include affected people in decision-making processes and guarantee the respect of basic human rights.
The CDB needs to improve stakeholders’ engagement practices and ensure the protection of indigenous heritage
After years of overcoming extractive colonialism, Indigenous communities in the culturally diverse Caribbean region now face a new threat: climate change. This crisis jeopardizes not only their material assets, including ancestral lands and properties, but also their very way of life and the rich tapestry of their cultural heritage. To avoid compounding existing harms, the CDB must prioritize the Free, Prior, and Informed Consent (FPIC) of Indigenous communities before any action is performed on their land. This aligns with the international obligations set out in the UN Declaration on the Rights of Indigenous Peoples (2007) and the ILO Convention 169 on Indigenous and Tribal Peoples (1989).
Beyond FPIC, meaningful stakeholder engagement is crucial. The CDB must actively involve all stakeholders, including vulnerable groups, in project design, implementation, and monitoring. If relevant procedures exist, the CDB must ensure they are clearly disclosed and readily accessible to all stakeholders, especially those facing vulnerability or geographic barriers to information. Unfortunately, current disclosure practices suggest the CDB does not adequately facilitate this crucial process.
The CDB’s stakeholders’ engagement practices reveal a complete lack of compliance with international norms and standards, which stands out when compared to most development financial institutions we already analyzed. Only one out of 84 projects (1.2% of the dataset) we analyzed referenced a Stakeholder Engagement Plan (SEP). Disappointingly, this crucial document was absent from the designated disclosure page, as well as unfindable on the CDB’s website, limiting public access and transparency. In addition, none of the reviewed project disclosures outlined procedures for consulting with project-affected communities and affected stakeholders’ involvement in decision-making.
The CDB needs to improve the disclosure and accessibility of contact information
The CDB’s practice of not disclosing lead contact information likewise raises concerns about transparency. Only a few projects, among the ones we analyzed, have included limited contact information for the borrower or client (4 out of 84, or 4.8% of the dataset) and project-specific bank leads (33 out of 84, or 39.3% of the dataset). However, this information was not available on the project disclosure webpage and was instead only available within project documents (in 1 out of the 4 projects for borrowers or clients, and in 32 out of 33 projects for the project-specific bank leads).
Adding another layer of accessibility, these documents were not linked or accessible from the designated disclosure pages. Rather, the research team had to conduct an extensive manual search on the CDB’s website to find these documents. This fact shows that the CDB still has to improve the accessibility of contact information to ensure they can be easily consulted by those who most need it, such as project-affected communities. Increasing the accessibility of project contact information would also positively reflect on the bank’s accountability throughout project implementation.
Similarly, the CDB also does not regularly disclose procurement information for those projects where private actors are involved. Such information was missing in 55 of the projects we analyzed (65% of the dataset). Enabling access to procurement information is important for communities and stakeholders to understand what actors are involved in those projects that affect them. It also saves time as they can directly contact the project implementers without relying on the CDB’s involvement as an intermediary.
Finally, further compounding issues of transparency and accountability, project disclosure pages do not provide information about the CDB’s accountability mechanisms, or links for submitting information requests. Only the CDB headquarters’ address, and a general phone number — not specifically associated with any person or department — are provided on the project disclosure pages. These conditions make it incredibly challenging for affected communities and stakeholders to access relevant information or report issues to the bank’s independent compliance mechanisms.
A call for action: the CDB must change
According to our analysis, the CDB needs to improve on transparency and accountability to align itself with the best practices of other MDBs. Unless it will promptly do so, the human rights of people in the Caribbean may be threatened.
Here are a few urgent requirements to fulfill:
- First of all, essential project documents — such as the ones outlining environmental and social impacts and the related safeguards — should be readily available and easily accessible by affected communities;
- To guarantee full inclusivity and recognition of the region’s cultural diversity, the CDB must disclose project documents in the languages of the Caribbean — especially those of the project-impacted area — including Creole, Haitian, and Papiamentu. This is an essential step to guarantee communities’ right to access information;
- The CDB shall involve stakeholders throughout the project cycle, publishing up-to-date stakeholder engagement plans in a timely manner, so as to allow project-affected communities to meaningfully participate in project design, implementation, and assessment; and
- Last but not least, the CDB must provide clear and precise information, possibly including them in project disclosure pages, on its grievance redress mechanisms. This would increase the bank’s accountability towards communities impacted by its investments.
Although we appreciate that the change might take some time, we hope that the CDB will soon improve its practices, to guarantee Caribbean communities’ basic human rights and a more sustainable development of the region.
In Latin America and the Caribbean, the Early Warning System is co-administered by a network composed of Cohesión Comunitaria e Innovación Social, Colectivo sobre Financiamiento e Inversiones Chinas, Derechos Humanos y Ambiente, Fundación para el Desarrollo de Políticas Sustentables, Instituto Maíra, Interamerican Association for Environmental Defense, Sustentarse, and Plataforma Internacional Contra la Impunidad.
Alessandro Ramazzotti is the researcher focusing on the Early Warning System at the International Accountability Project. He is originally from Italy but constantly changes his base.
Anggita Indari is the Communications Coordinator at the International Accountability Project. She is based in Indonesia.
