World Bank EHS

Red LineText of policiesCommentsScore
Regulatory requirements
Ensure LegalityEHS Guidelines: When host country regulations differ from the levels and measures presented in the EHS Guidelines, projects are expected to achieve whichever is more stringent." (p1)This implies a requirement to comply with national laws, but not with international ones.Party
No Corruption and Tax Evasionnot covered in the policynot
Ensure ESIA for mills and plantationsnot covered in the policynot
Social requirements
Ensure FPICnot covered in the policynot
Respect Human Rightsnot covered in the policynot
Respect Indigenous rights and customary land use rightsnot covered in the policynot
No forced resettlementnot covered in the policynot
Environmental Requirements
No forest degradation and deforestationEHS forestry: It is recommended to :
* Biodiversity reserves should be created, managed, and monitored, to protect critical natural habitat, and high conservation value forest as representative samples of existing ecosystems in their natural state; (p3)
* Ensure that any natural or modified habitat to be converted to plantation forest does not contain critical habitat, including known habitat of critically endangered or endangered species, or important wildlife breeding, feeding, and staging areas; Identify the presence of critically endangered or endangered species in areas already used for plantation forest and ensure that their habitat is appropriately managed;
* Set aside any identified critical habitat for biodiversity conservation purposes and for eventual restoration of the natural forest cover. (p4)

EHS Perennial crops
21. Impact avoidance should be the goal. (...) Early screening (...) to avoid selecting areas with high biodiversity values,
such as critical or natural habitat, areas with high conservation values (HCV), those modified habitats that contain significant biodiversity value (...) or provisioning or regulating ecosystem services. (...) Sites of local, regional, and international importance21 may include: nationally and internationally protected areas, Important Bird Areas (IBA), Key Biodiversity Areas (KBAs), Alliance for Zero Extinction (AZE) areas, Ramsar Sites (Wetlands of International Importance), along with known congregatory sites and unique or threatened ecosystems. (p12)
There are recommendations for forest and plantation management, to protect biodiversity, but there is no clear prohibition on the conversion of natural forests or HCV forests. There is no mention of HCS areas.partly
Protect endangered speciesEHS Forestry: it is recommended to :
* Ensure that any natural or modified habitat to be converted to plantation forest does not contain critical habitat, including known habitat of critically endangered or endangered species, or important wildlife breeding, feeding, and staging areas;
* Identify the presence of critically endangered or endangered species in areas already used for plantation forest and ensure that their habitat is appropriately managed;

EHS Perennial crops
21. (...) Screening should be conducted to identify species and sites of importance within the broader region or landscape. (p12)
There are recommendations to protect endagered species, but no clear prohibition to trade in protected species; It does not mention third party operationspartly
No high-risk speciesEHS Forestry: Exotic Species
Forest operators should not intentionally introduce any new alien species (...) unless this is carried out in accordance with the existing regulatory framework for such introduction, if such framework is present, or is subject to a risk assessment (as part of the Social and Environmental Assessment) to determine the potential for invasive behavior.
Operators will not deliberately introduce any alien species with a high risk of invasive behavior or any known invasive species, and will exercise diligence to prevent accidental or unintended introductions. Operators should also take precautions to prevent the spread of existing exotic species as a result of forestry operations.(p5)

EHS Perennial Crops:
26. Developers should seek to avoid the introduction of invasive species, as well as control and reduce their further spread.
29. The introduction of GM perennial crops should be conducted in compliance with the host country’s regulatory framework. If such a regulatory framework does not exist in the host country, the applicability of the Cartagena Protocol on Biosafety should be verified and used to scientifically evaluate the potential impacts and risks related to a specific crop’s introduction, including its invasive potential, and identify appropriate mitigation measures. The next steps in the risk assessment are to evaluate the likelihood of the events occurring, the consequences if it happens, and whether the overall risks (i.e., consequence and
likelihood) are acceptable or manageable.
The recommendations regarding alien species are limited to legal compliance, and the same is true for the introduction of GMOs.partly
No fireEHS Forestry:
Prescribed burns may be used as a land management technique to reduce the presence of excessive wood fuel (e.g slash) and decrease wildfire risk; to prepare the land for replanting / seeding; and to provide natural forest regeneration cycles for certain species, in addition to other uses.(p14)

EHS Perennial Crop
45. Management plans and operating procedures should include comprehensive strategies for the prevention, detection, and suppression of fires within plantation perimeters and adjacent properties, including: (...)
• Means to access and contain fires within plantation premises;
There is no clear prohibition on the use of firenot
Protect peatNo mention of protection for peat of HCS in any of the 3 policiesnot
No persistent pollutionWB General EHS Guidelines - Ambient Air Quality - General Approach: Projects with significant sources of air emissions (...) should prevent or minimize impacts by ensuring that:
· Emissions do not result in pollutant concentrations that reach or exceed relevant ambient quality guidelines (...)
· Emissions do not contribute a significant portion to the attainment of relevant ambient air quality guidelines or standards. (p4)
Discharges of (...) wastewater (...) should not result in contaminant concentrations in excess of (...) ambient water quality criteria (p26)

EHS Pulp and Paper mills - Pulp mill wastewater treatment should typically include primary treatment (...) and, less frequently, tertiary treatment to further reduce toxicity (...) (p4); Avoid the use of elemental chlorine for bleaching ; (p10)

EHS Forestry - Avoid the use of pesticides that fall under the WHO Recommended Classification of Pesticides by Hazard Classes 1a and 1b; Avoid the use of pesticides listed in Annexes A and B of the Stockholm Convention, except under the conditions noted in the convention; (p11)

EHS Perennial Crops - 19. A pesticide management plan (...) should be prepared in accordance with FAO guidelines and (...) consistent with (...) commitments under the Stockholm, Rotterdam, and Basel Conventions.
• Do not purchase, store, use, or trade pesticides that fall under the WHO Recommended Classification of Pesticides by Hazard Classes 1a and 1b, or Annexes A and B of the Stockholm Convention.
• Do not use pesticides listed in WHO Hazard Class II, unless the project has appropriate controls established (...)(p9)
The EHS have detailed guidelines but no clear prohibition on causing persistent pollution. Secondary treatment is recomnneded, but not compulsory; Elemental chlorine should be avoided, but is also not forbidden; partly
Corporate association / scope of the policy
Corporate association / scope of the policyNo mention of appliance of policy to third parties in any of the three policiesnot