The World Bank Denies Indigenous Peoples their Right to Prior, Informed Consent

 Ted Downing and Jerry Moles

Reprinted from Cultural Survival Quarterly. Winter 2001

On 23 October 2001 , The World Bank Governing Board denied indigenous peoples the right of prior informed consent if they are threatened with involuntary resettlement.  Its President, James Wolfensohn, clarified his hardening position on indigenous peoples’ rights.   Wolfensohn recommended the Bank Board ignore the pleas of scores of non-governmental organizations, tribes and activists who were fighting to assure indigenous peoples the right of prior informed consent in situations where they are threatened with resettlement.   In an September 28 letter, he wrote that the new involuntary resettlement policy:

“does not incorporate provisions requiring prior, informed consent of indigenous peoples to resettlement. Instead, it calls for meaningful consultations with and informed participation of all potentially displaced persons. …The reasons for not including such a provision are the following: the concept of prior, informed consent is very difficult to operationalize; it is not reflected in the legal framework of any country, whether developing or developed; it is contrary to the principle of eminent domain in effect in most countries.” 

 The Board accepted his recommendation and passed the new Involuntary Resettlement policy (OP 4.12) on 23 October.

 New Indigenous Peoples Policy awaits Public Comments

 And even more ominous storm clouds are gathering on the horizon.  On 5 July, The World Bank quietly uploaded its long anticipated, new indigenous peoples policy for public comment (Operational Policy 4.10 and its associated Bank Procedures 4.10). The revision began in 1998 with a worldwide consultation on the Bank’s Approach Paper. One of ten regional consultations took place in Orissa (about 8m tribals in 2001), attended by 25 people. The Mexico and Central America (~14m indigenous people) consultation took place in Costa Rica (~30K indigenous people) and included 40 representatives from the government's side and from indigenous associations.  Following these global consultations, the revised policy was drafted.  The Bank is now requesting comments be sent before 14 December 2001 . 

The fuse is short, but the issue is critical. The Bank states that its revision is being carried out to “clarify ambiguities and processing requirements, facilitate implementation, incorporating lessons learned from implementing its indigenous peoples policy over the last two decades. Translated, this means that someone in the Bank’s management, staff, private sector clients, and/or member governments is dissatisfied with the current policy.  Complaints from indigenous peoples about the current policy (Operational Directive 4.20 from 1991) have been limited and focused on questions of compliance rather than the policy itself. Few are even aware that there is a global indigenous policy concerning those who are in-the-way-of-development. 

Strong political forces are working behind the scenes.  Rather than conspiracy, this means a conflict among stakeholders with unequal power – both inside and outside the Bank.  Demystified, The World Bank is a very large credit union, consisting of member nations whose power is roughly proportionate to their financial contributions.  It is managed by almost autonomous Beltway staffs that come from many cultures and disciplines, but mostly from the upper and upper-middle class SES strata.  This creates a special mix of knowledge, ignorance, and ambivalence about poor indigenous people.  There is also a small beachhead of pro-indigenous rights advocates working inside the Bank, albeit in rather powerless positions. Given the sensitive nature of indigenous and tribal peoples status in many countries, it can be anticipated that government stakeholders will view the emergence of an international standard as an affront to national sovereignty, unless it strengthens governmental control of “their indigenous” people and their lands. 

Activists and NGOs fighting for indigenous peoples rights are also ambivalent about the indigenous policy. Many prefer to focus on issues of systematic non-compliance with the existing indigenous policy.  While they see the advantage in an international standard that strengthens the notoriously weak positions of indigenous peoples within their own nation-states, they are also skeptical that any international guidelines will be reflected in a more just, due process at home. 

An alternative theory, espoused by some of the Bank staff is that the policy’s release is not such a big deal.  The Bank is simply releasing new draft guidelines for its management and staff to follow when they prepare loans.  From this perspective, the draft policy applies only to indigenous peoples who find themselves in the way of development projects financed by the Bank – not to all indigenous people.  In sum, The World Bank is not launching a global standard (who named this institution in the first place?).  

In other forums, the Bank has argued that its policies set a global standard for the obligations and responsibilities of financial institutions and their borrowers to indigenous people who are in the path of their projects. Compared to international declarations and resolutions, these standards have some teeth, since they are one item on a long checklist that must be completed in order for a project to access capital.   The World Bank participates in only a small fraction of world’s development projects; nonetheless it has developed some of the most stringent international environmental and social standards among global financial organizations.  Project financiers and promoters who are working on sensitive environmental and social projects take pride in claiming their projects include participation of The World Bank or meet its guidelines.  Changes in this standard will have powerful downstream repercussions.  

Why are the Bank Indigenous Peoples Policy so Important?

An interesting financial twist works in favor of indigenous peoples and underscores the significance of commenting on the Bank’s revised draft of its policy.    Members of syndicates who finance large projects usually have distinct environmental and social policies. To maintain the integrity of the investment group and keep the project moving forward, the syndicate—as a group—is restricted by the most stringent policy of any one of its members. This may turn out to be a minority shareholder. International lenders, including The World Bank Group, hold such positions.  The failure of a borrower to adhere to a lender’s policy may force the lender to pull out of the project.  A lender’s withdrawal from a project may raise doubts over the viability of a project within the financial community.   No financing, no project. This means that close attention should be paid to the environmental and social requirements of project investors—especially those with the most stringent policies.  In the case of indigenous peoples policies, this turns out to be The World Bank.

Terminating indigenous people by definition

I will reserve my full analysis of the policy until later. There are some good ideas in the draft, but I want to point out a few places that merit critical thinking.  Despite the Bank’s claim that the revision of its indigenous policy is not intended to alter the current policy’s key objectives, there are significant changes – especially in defining who is eligible for project benefits and safeguards.   The policy must, at minimum, provide an internationally applicable definition of who are and are not indigenous peoples.  The new policy language closely tracks the current one.  It defines indigenous people by the presence, in varying degrees, of some of the following distinctive characteristics 1) close attachment to ancestral territories and the natural resources in them; (2) presence of customary social and political institutions; (3) economic systems primarily oriented to subsistence production; (4) an indigenous language, often different from the predominant language; and (5) self-identification and identification by others as members of a distinct cultural group.”  

The proposed policy significantly and radically departs from current Bank policy by excluding from its provisions those groups who (a) have left their communities of origin, (b) moved to urban areas, (c) and/or migrated to obtain wage labor.  Certainly the proposed policy is not a product of indigenous thinking. If this language is adopted a waterfall of ugly things are likely to happen to indigenous people. Impoverishment has led many of the world’s indigenous people to leave their communities, move to urban areas, and find temporary jobs as laborers.   Although absent, many of these people maintain close links with their communities, hold rights to ancestral lands, and provide financial support for civil and cultural services. Such is the case of tens of thousands of Oaxacan indigenous migrants who are working in the United States and Mexico City .  The proposed policy unjustifiably excludes these and millions of other indigenous peoples from eligibility. It creates an international definition that governments may use to justify claims that indigenous peoples within their borders are not really indigenous. And worse, the proposed policy thrusts an external policy wedge deep into indigenous social structure, creating two classes of people who are eligible for benefits and risk mitigation.  In the chaos I have witnessed accompanying project development over the past three decades, the destructive potential of this new clause should not be underestimated (www.ted-downing.com). How can Bank policy override the rights inherent in the relations between families, people and their culture? This exclusionary clause is a direct affront to the sovereignty, traditional rights and the body politic of indigenous people.   It should be immediately removed and not replaced with compromise language.  

Unanswered questions

Unresolved issues await your suggestions. What changes might resolve the serious, internal conflicts of interest for Bank management, staff and borrowers – including their setting the time line and ground rules for consultation and information flow? What improvements might increase the likelihood of opportune, informed consent and participation? Are provisions in policy made to assure that indigenous people subjected to adverse project impacts are beneficiaries and share in the profits of projects and are not simply compensated for losses? Are provisions made to end the inherent human rights violations that occur when the Bank and borrowers draw up secret agreements over the future of indigenous groups without the informed consent of either the indigenous group and government? 

Building on the comments made during the limited global consultation, why doesn’t the draft strengthen the protection of indigenous ancestral lands and resources that are so critical to their cultural survival?  Why are the adverse impacts of structural adjustment operations to indigenous peoples explicitly excluded form the policy? Why does the draft policy open up a procedure for the involuntary resettlement of indigenous peoples? Why doesn’t the draft policy rank  self-identification as the MAIN criterion which triggers application of the policy as requested by indigenous peoples and in accordance with ILO 169 and the Draft UN Declaration on the Rights of Indigenous Peoples? Why is there no requirement for participatory monitoring and involvement of indigenous peoples in the governance of projects and programs that affect them? And why does the policy empower the borrower rather than the indigenous people with the right to prepare an indigenous peoples development plan (see, for example, the quality work of David Maybury-Lewis, Ian McIntosh, and so many more who are working with Cultural Survival, including their Fall issue of Cultural Survival Quarterly on the option called “Plan B”).

The Bank claims the revised policy incorporates lessons learned from implementing the indigenous peoples policy over the last two decades. What lessons are being incorporated?  With the policy commentary deadline on 31 October, the World Bank's quality control arm, known as the Operations Evaluations Department (OED), finally initiated a long delayed review of the way Bank operations have affected indigenous peoples during the 1990s.  This OED review – that should put forth the lessons learned, will not be released until one month after public commentaries on the proposed indigenous policy is completed.  How could the lessons learned be considered in the commentary if the public review is not completed until after the deadline for public commentary?  Will the Bank management dismiss critical commentaries claiming that new information from their internal OED review overrides external public comments?  Is this a bureaucratic inefficiency, a cruel hoax, or cynical disregard for the public commentary process?  Why not delay the deadline until after civil society has had an opportunity to review the results of the Bank’s internal review?  

The policy comes in two pieces: Operational Policies 4.10, for the borrower/bank agreements, and Bank Procedures 4.10 intended for Bank management and staff.  Rapid access to both these documents is available by going to www.policykiosk.com.  Of these, OP 4.10 is the critical document, since it is likely to be incorporated into legally binding loan agreements.  A common move in Bank policy crafting is to shift critical lines from the Operational Policies to such non-binding documents such as the toothless Bank documents called Good Practices.  While it might be great fun for late night academic policy discussions – the Good Practices issues are irrelevant and detraction from binding policies and agreements.

How to comment

Anyone who claims an interest in indigenous people should set aside some time to read the old and new policies and answer the Bank’s call. I highly recommend undergraduate, graduate and non-academic community study groups deconstruct the policy and prepare comments to the Bank. The comments are strongest when the policy is marked-up and annotated line by line and includes constructive, alternative language and suggestions.  I have tried this twice in class and the student-citizens have produced high quality, substantive comments that have nudged international policy.

 The website www.policykiosk.com provides a quick connection to the current and proposed policies. Once at the Bank website, you will discover The Bank’s electronic consultations are being carried out in at least three languages: English, Spanish, French, and, it appears, other languages. No translation is planned into any indigenous language. They provide a simple, web-based form for feedback on the draft policy. I recommend people avoid using their filling-in-the-box, on-line form.  It leaves no reliable political paper trail.  A more effective way to make certain your voice is heard is to submit an old fashion letter to the Bank, along with an email and a copy to the members of your respective legislative oversight committees, your local elected representatives, your national Executive Director to The World Bank group, and the www.policykiosk.com.  The kiosk publishes all commentaries as they were mailed to The Bank. 

Ted Downing ([email protected] and www.ted-downing.com) and Jerry Moles ([email protected]) are activists anthropologists.  Downing filed the first and only internal human rights complaints ever made inside The World Bank regarding their mistreatment of the Pehuenche Indians in Chile .  Rejected by the Bank, his complaints were subsequently upheld by the Human Rights Committee of the American Anthropological Association.  Downing is Research Professor of Social Development, Arizona Research Laboratories, the University of Arizona and Moles directs the Neosynthesis Research Center .