Skip to main content
SpringerLink
Log in

Operational Standards: Environmental and Social Framework 2021

  • Chapter
  • First Online:
Chinese Multilateralism in the Asian Infrastructure Investment Bank (AIIB)

Part of the book series: Modern China and International Economic Law ((CIEL))

  • 17 Accesses

Summary

The AIIB’s new Environmental and Social Framework (ESF) features a relationship of heritage and innovation, compared with the ESF of the World Bank and other multilateral development banks (MDBs). The innovative elements are not only embodied in a few specific institutions shiny with traditional Asian wisdom of ‘voluntarism, flexibility and incremental progress’, but are also observed in the AIIB’s frontier environmental, social and governance portfolio investments in global capital markets. Drawing upon the World Bank, the alternative use of client systems enables the AIIB to maintain high and feasible standards, without having to intervene in national politics. In the Project-affected People’s Mechanism, three complaints resolution functions are streamlined under one roof, catering for the nature and degree of seriousness of the dispute involved and marking a major innovation in the design of an accountability mechanism among leading MDBs. The two requirements of exhaustion of project-level remedies and free, prior and informed consultation expect to function equivalently to the World Bank standards in effect, although they appear to reduce the protection of project-affected people.

This chapter originally appeared in Review of European, Comparative & International Environmental Law, 5 September 2022, entitled “A legal study of the AIIB’s new Environmental and Social Framework”.

This is a preview of subscription content, log in via an institution to check access.

Access this chapter

Log in via an institution
Chapter
USD 29.95
Price excludes VAT (USA)
  • Available as PDF
  • Read on any device
  • Instant download
  • Own it forever
eBook
USD 119.00
Price excludes VAT (USA)
  • Available as EPUB and PDF
  • Read on any device
  • Instant download
  • Own it forever
Hardcover Book
USD 159.99
Price excludes VAT (USA)
  • Durable hardcover edition
  • Dispatched in 3 to 5 business days
  • Free shipping worldwide - see info

Tax calculation will be finalised at checkout

Purchases are for personal use only

Institutional subscriptions

Notes

  1. 1.

    The quote is from a statement by then AIIB President-designate Jin Liqun; it has been reiterated both in AIIB official documents and on the AIIB’s official website. See AIIB, ‘Statement by Jin Liqun at a Press Conference in Tbilisi’ (26 August 2015) < https://www.aiib.org/en/news-events/news/2015/Statement-by-Jin-Liqun-at-a-Press-Conference-in-Tbilisi.html > .

  2. 2.

    The three words are commonly defined as follows: ‘lean’, meaning with a small, efficient management team and highly skilled staff; ‘clean’, meaning an ethical organization with zero tolerance for corruption; and ‘green’, an institution that is built on respect for the environment. Nevertheless, the technical definitions vary across AIIB official documents.

  3. 3.

    ‘Major policies’ is a legal term defined to explicitly include the ESF, and they require a higher three-quarters majority of total voting power within the Board of Directors for approval. By comparison, ‘other policies’ require a simple majority of the votes cast within the Board of Directors for approval. AIIB, ‘Articles of Agreement’ < https://www.aiib.org/en/about-aiib/basic-documents/articles-of-agreement/index.html > (AIIB AOA) art 26.2 and Explanatory Notes on Article 26 as attached to the Chief Negotiators’ Report on AIIB AOA.

  4. 4.

    Of the first batch of AIIB projects located in Bangladesh, Indonesia, Pakistan and Tajikistan, totalling US$509 million in loans, three projects were co-financed with peer institutions including the World Bank, the Asian Development Bank (ADB), and the European Bank for Reconstruction and Development (EBRD), and those projects applied the co-financers’ ESFs, respectively, with each considered to be ‘materially consistent’ with AIIB’s ESF; the only project using the AIIB’s own ESF was the standalone one in Bangladesh. The AIIB 2016 ESF explicitly authorized the use of the co-financier’s ESF, stating that ‘[t]he Bank may agree, on a case-by-case basis, to the application of the environmental and social policies and procedures of multilateral development banks and bilateral development organizations who are co-financing the Project, provided that the Bank is satisfied that they are consistent with the Bank’s Articles of Agreement and materially consistent with the ESP and ESSs, and that appropriate monitoring procedures are in place’. AIIB, ‘2016 Environmental and Social Framework’ (February 2016) (AIIB 2016 ESF) ‘Environmental and Social Policy (ESP)’, para 10.

  5. 5.

    The 2016 ESF warranted that ‘updates would be introduced to the framework, and further improvements to the ESP and ESSs would be recommended to the Board of Directors for approval’ at the end of ‘the first three years of the Bank’s operation’. AIIB 2016 ESF (n 4) ‘Introduction’, para 4.

  6. 6.

    The PPM was established in accordance with the Policy on the Project-affected People’s Mechanism in 2018, during the interval between the 2016 and 2019 ESF of the AIIB. See AIIB, ‘Policy on the Project-affected People’s Mechanism’ (7 December 2018) < https://www.aiib.org/en/policies-strategies/operational-policies/policy-on-the-project-affected-mechanism.html > (AIIB Policy on the PPM).

  7. 7.

    In a non-missionary culture, China has never sought to export its political system and values; rather, it has seen others come to it. As Confucius said, ‘远人不服，则修文德以来之’ (translated literally as: If people from afar do not submit, influence them to do so by means of virtue and civil culture). For an elaboration of this aspect of the Chinese culture, see H Kissinger, World Order (Penguin Books 2015) 213–233.

  8. 8.

    As Deng Xiaoping famously said: ‘Be it a black cat or a white cat, it is a good cat as long as it can catch mice’.

  9. 9.

    Some regional MDBs still use the traditional name of safeguards, such as the ADB and the African Development Bank (AfDB), while others adopt the term ESF, such as the AIIB, the New Development Bank (NDB) and the Inter-American Development Bank (IDB).

  10. 10.

    The EBRD may be considered an exception in the sense that it was created in 1991 to promote privatization in the former Soviet Union countries.

  11. 11.

    An overview of the evolution from economic growth to more inclusive aspects in the understanding of sustainable development can be found in P Dann, The Law of Development Cooperation (Cambridge University Press 2013) 101–125.

  12. 12.

    The genesis of the World Bank’s ESF was the Operational Manual Statement on Environmental Aspects of World Bank Work (OMS) in 1984, subsequently updated as Operational Directives (ODs) in 1987, as Operational Policies and Bank Procedures (OP/BP) in 1992, as safeguard policies in 1997, and ultimately, bearing the current name of ESF in 2016.

  13. 13.

    The notion of droit commun is defined as a process through which various organizations develop and implement similar standards, rules or procedures. A droit commun allows for the emergence of a distinct legal corpus of the harmonized standards, rules and procedures that the institutions have in common. See L Boisson de Chazournes, ‘Partnership, Emulation, and Coordination: Toward the Emergency of a Droit Commun in the Field of Development Finance’ in H Cisse, DD Bradlow, B Kingsbury (eds), The World Bank Legal Review, Vol. 3 (World Bank 2012) 174. The AIIB ESF’s explicit authorization of the use of a co-financer’s ESF in an AIIB-financed project, as discussed above, may contribute to the prospect of a droit commun.

  14. 14.

    The World Bank means the International Bank for Reconstruction and Development (IBRD) and the International Development Association (IDA). The World Bank ESF was drafted from 2012 through 2016, a period largely coinciding with the establishment of the AIIB. Presumably, the AIIB’s ESF had been built upon that of the World Bank, with the assistance of a former World Bank senior expert, Stephen Lintner.

  15. 15.

    Under the World Bank Group, IBRD/IDA serves the public sector, and IFC/MIGA serves the private sector, applying different safeguard systems. See IFC, ‘Sustainability Framework’ (1 January 2012) < https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sustainability-at-ifc/publications/publications_handbook_sustainabilityframework > . By contrast, other MDBs, such as the AIIB, ADB, AfDB, European Investment Bank (EIB) and IDB, which are eligible to invest in both public and private sectors, apply the same operational safeguards to both sectors, with their procedural requirements adjusted to the particular circumstances of private sector activities.

  16. 16.

    All the texts of these internal laws are readily available on the AIIB’s official website: < https://www.aiib.org/en/index.html > .

  17. 17.

    The non-resident Board of Directors shall ‘supervise the management and operation of the Bank on a regular basis, and establish an oversight mechanism for that purpose, in line with principles of transparency, openness, independence and accountability’. AIIB AOA (n 3) art 26(iv).

  18. 18.

    For a detailed discussion of this policy, see B Gu, The Law and Governance of the Asian Infrastructure Investment Bank (Wolters Kluwer 2019) 143–172.

  19. 19.

    To be accurate, the scope of AIIB investments breaks down into two elements under AIIB AOA (n 3) art 1(1): ‘infrastructure’ and ‘other productive sectors’. ‘Infrastructure’ itself is a broad sector encompassing both physical and electronic elements. The concept of ‘other productive sectors’ can be even broader, echoing the term ‘productive’ first used in the International Bank for Reconstruction and Development (IBRD) Charter in 1944, whereby the word choice meant to exclude ‘such non-productive lending as financing of war and budget deficits and refinancing of old debts’. N Lichtenstein, A Comparative Guide to the Asian Infrastructure Investment Bank (Oxford University Press 2018) 42–43, 50–51.

  20. 20.

    These sector-specific strategies include the Transport Sector Strategy, Sustainable Cities Strategy, Water Strategy, Digital Infrastructure Sector Strategy, etc.

  21. 21.

    AIIB,‘ENergy Sector Strategy: Sustainable Energy for Tomorrow’(Nov. 22, 2022), paras. 53–58. A discussion of no-coal investments in international development is available at B Gu, ‘China’s Belt and Road Initiative Should Stop Financing New Coal Power’ (Financial Times, 5 July 2021).

  22. 22.

    AIIB, ‘Corporate Strategy: Financing Infrastructure for Tomorrow’ (September 2020) 27.

  23. 23.

    The text of this strategy can be found at < https://www.aiib.org/en/policies-strategies/strategies/financing-operations.html > . For a detailed critique of the AIIB’s non-regional investment policy, see B Gu, ‘AIIB Should Broaden Horizons to Gain Global Impact’ (Global Times, 16 December 2018).

  24. 24.

    The Board shall ‘take decisions concerning operations of the Bank’, and ‘by a majority representing not less than three-fourths of the total voting power of the members, decide on the delegation of such authority to the President’. AIIB AOA (n 3) art 26(iii).

  25. 25.

    While the internal organs competent to enact internal laws are many, the Board of Directors is deemed as the “legislative” branch, if roughly compared to the national system.

  26. 26.

    The three sources of international law, as stipulated in Article 38 of ICJ Statute, are: international conventions, international custom, and general principles of law.

  27. 27.

    Malcolm N. Shaw, International Law (Cambridge University Press 2008, 6th ed.), pp.70–71.

  28. 28.

    It is noted that Article 38 of ICJ Statute was primarily drafted for the Permanent Court of International Justice during the inter-war period, well before international organizations became proliferated after World War II. James Crawford, Brownlie’s Principles of Public International Law (Oxford University Press 2012, 8th ed.), pp.21–22.

  29. 29.

    In this light Alvarez criticizes that ‘we continue to pour an increasingly rich normative output [of international organizations] into old bottles labeled “treaty,” “custom,” or (much more rarely) “general principles”’. Jose E. Alvarez, International Organizations as Law-makers (Oxford University Press 2005) Preface p. x.

  30. 30.

    Malcolm N. Shaw, International Law (Cambridge University Press, 2008, 6th ed.), pp.98–99.

  31. 31.

    It is noted that the degree of legal personality and corporate will varies across international organizations, ranging from the contractual type (such as Shanghai Cooperation Organization, SCO), to the constitutional type (such as European Union, and, to a lesser extent, the AIIB).

  32. 32.

    White comments that ‘even though the term “legislation” is often confined to hard lawmaking, there is no reason why its meaning—as the process of enacting law—should not be extended to softer forms of lawmaking.’ Nigel D. White, ‘Lawmaking’, in Jacob Katz Cogan, Ian Hurd, Ian Johnstone (eds), The Oxford Handbook of International Organizations (New York: Oxford University Press 2016), p. 566.

  33. 33.

    AIIB AOA, Article 13.4.

  34. 34.

    This quote of White is believed to contribute to the legitimacy of a norm. Nigel D. White, ‘Lawmaking’, in Jacob Katz Cogan, Ian Hurd, Ian Johnstone (eds), The Oxford Handbook of International Organizations (New York: Oxford University Press 2016), p. 569.

  35. 35.

    As Dann and Riegner comment, “the Safeguards had become a globally diffused normative model for socially and environmentally sound development”, by way of “diffus[ing] horizontally into the laws and practices of other MDBs and private banks and vertically into domestic legal orders beyond individual projects”, eventually transcending the World Bank “from lender to norm-setter”. Philipp Dann and Michael Riegner, “The World Bank’s Environmental and Social Safeguards and the evolution of global order”, Leiden Journal of International Law (2019), 32, pp. 538, 545–7.

  36. 36.

    It is a language borrowed from Article 38 of ICJ Statute.

  37. 37.

    The three ESSs are entitled, respectively, ‘Environmental and Social Assessment and Management’, ‘Land Acquisition and Involuntary Resettlement’ and ‘Indigenous Peoples’.

  38. 38.

    While the text of a project agreement is not publicly available, a summary of each project is posted on the AIIB official website as a ‘looking glass’ into how the ESF governs. For example, regarding the Oman Broadband project, it states: ‘According to AIIB’s Environmental and Social Framework, the Project is classified as Category B. As required for a Category B project, an Environmental and Social Management Plan (ESMP) has been developed’; AIIB, ‘Oman: Oman Broadband Infrastructure’ < https://www.aiib.org/en/projects/details/2017/approved/Oman-Oman-Broadband-Infrastructure.html > . Regarding another project, the Beijing coal-to-gas project, it similarly states: ‘Per the Bank’s Environmental and Social Policy, the Project is assigned as Category B. As part of Project preparation, the environmental and social impacts were assessed and mitigation measures proposed in an Environmental and Social Management Plan (ESMP)’; AIIB, ‘China: Beijing Air Quality Improvement and Coal Replacement’ < https://www.aiib.org/en/projects/details/2017/approved/China-Beijing-Air-Quality-Improvement-and-Coal-Replacement.html > . The ESMP is a commitment made by the borrower and approved by the AIIB, and the text of an ESMP is available on the websites of both the borrower and the AIIB.

  39. 39.

    Draft Articles on the Responsibility of International Organizations, in ‘Report of the International Law Commission, Sixty-Third Session’ UN Doc A/66/10 (2011) para 87ff.

  40. 40.

    See L Gasbarri, The Concept of an International Organization in International Law (Oxford University Press 2021) 41–44.

  41. 41.

    AIIB AOA (n 3) art 1(1).

  42. 42.

    AIIB, ‘Environmental and Social Framework (ESF)’ (May 2021) < https://www.aiib.org/en/policies-strategies/framework-agreements/environmental-social-framework.html > (AIIB ESF 2021) Vision, paras 29–30. The authorization of such special investments is derived from AIIB AOA (n 3) art 16(9), which states: ‘The Bank may exercise such other powers and establish such rules and regulations as may be necessary or appropriate in furtherance of its purpose and functions, consistent with the provisions of this Agreement.’

  43. 43.

    Specifically, capital markets investment is ‘governed by the terms of the publicly traded securities; the environmental and social assessment of any potential investment is made on the basis of publicly available information; reporting is made to all securities holders in the same manner; and environmental and social performance is more suitably assessed at the corporate rather than asset level by measuring publicly available ESG information against widely acknowledged benchmarks’. AIIB ESF 2021 (n 42) ESP, para 12.

  44. 44.

    AIIB, ‘Project Summary Information: Asia Climate Bond Portfolio’ PD000312 (22 April 2021) < https://www.aiib.org/en/projects/details/2019/approved/Multicountry-Asia-Climate-Bond-Portfolio.html > .

  45. 45.

    ‘[ESG portfolio] investments would require the use of an appropriate ESG framework against which environmental and social risks can be addressed.’ AIIB ESF 2021 (n 42) vision, para 29; and ESP, para 13.

  46. 46.

    AIIB, ‘Environmental, Social and Governance Credentials’ (April 2022) < https://www.aiib.org/en/treasury/_common/_download/AIIB-ESG-Credentials-Slides-20220401.pdf > 6.

  47. 47.

    K Horta and W Wang, ‘The Beijing-led Asian Infrastructure Investment Bank: Global Leader in Infrastructure Finance, at What Cost?’ (Heinrich Böll Foundation October 2021) 13, 29.

  48. 48.

    The AIIB’s Asia Climate Bond Portfolio, for example, ‘expects to mobilize another US$500 million from climate change-focused institutional investors’. AIIB (n 44).

  49. 49.

    With respect to the AIIB’s Asian ESG Enhanced Credit Managed Portfolio, for example, the investment focus is explicitly on quasi-sovereign bonds (e.g., those issued by State-owned enterprises), corporate bonds and green bonds; sovereign bonds, project bonds and derivatives are outside consideration. AIIB, ‘Project Summary Information: Asian ESG Enhanced Credit Managed Portfolio’ 000,152 (March 2019) < https://www.aiib.org/en/projects/details/2018/approved/Multicountry-AIIB-Asia-ESG-Enhanced-Credit-Managed-Portfolio.html > .

  50. 50.

    ‘[T]he Bank intends, in special circumstances, to support investments in a portfolio of publicly traded securities’. AIIB ESF 2021 (n 42) Vision, para 29 (emphasis added).

  51. 51.

    AIIB, ‘Corporate Strategy: Financing Infrastructure for Tomorrow’ (September 2020) 21.

  52. 52.

    ‘Mobilization by development finance institutions of financial resources for infrastructure development through investments in publicly traded securities (i.e. stocks and bonds) using environmental, social and governance (ESG) approaches is a new and dynamic frontier’; AIIB ESF 2021 (n 42) Vision, para 29 (emphasis added).

  53. 53.

    An exceptional provision, which is general in nature, is that ‘[g]iven the importance of the private sector’s role in the reduction of greenhouse gas (GHG) emissions, IFC will engage in innovative investments’. IFC (n 15) Policy on Environmental and Social Sustainability, para 10.

  54. 54.

    Statistics indicate that, among the top 20 countries for annual green bonds issuance in 2020, the United States led national rankings (US$51.1 billion), with Germany second (US$40.2 billion), France third (US$32.1 billion), China fourth (US$17.2 billion) and the Netherlands fifth (US$ 17 billion). See the Climate Bonds Initiative, ‘Record $269.5bn Green Issuance for 2020: Late Surge Sees Pandemic Year Pip 2019 Total by $3bn (24 January 2021) < https://www.climatebonds.net/2021/01/record-2695bn-green-issuance-2020-late-surge-sees-pandemic-year-pip-2019-total-3bn > .

  55. 55.

    Environmental Finance, ‘IMPACT Awards 2021’ < https://www.environmental-finance.com/content/awards/impact-awards-2021/corporate-statements/making-an-impact-in-asian-infrastructure.html > .

  56. 56.

    AIIB, ‘Asia Climate Bond Portfolio ESG Framework’ (Version 1, March 2020) < https://www.aiib.org/en/projects/details/2019/approved/_download/Multicountry/ESG-Framework-for-ACB-Portfolio-April-9-2020.pdf > 7–8.

  57. 57.

    AIIB, ‘AIIB-Amundi Climate Change Investment Framework’ < https://www.aiib.org/en/policies-strategies/framework-agreements/climate-change-investment-framework/index.html > .

  58. 58.

    At the time of writing, the AIIB is rated C + in terms of ESG performance. Among the 32 peer institutions rated by ISS ESG, an ESG rating agency, only three, as industry leaders, have ratings higher than C + ; they are the ADB (B), the Council of Europe Development Bank (CEB) (B-) and the EBRD (B-). See < https://www.aiib.org/en/treasury/esg/index.html > .

  59. 59.

    An investor-paid, rather than issuer-paid, rating arrangement helps to avoid the notorious conflicts of interest that exist in the credit rating industry and contributed to the 2008 global financial crisis.

  60. 60.

    The authority of portfolio investments is retained by the Board, rather than being delegated to the President as had been expected in the institutional context of a non-resident Board of the AIIB. AIIB ESF 2021 (n 42) ESP, para 14.

  61. 61.

    AIIB, ‘Asian ESG Enhanced Credit Managed Portfolio ESG Framework’ (Version 1, July 2019) 3–4. < https://www.aiib.org/en/projects/approved/2018/_download/regional/ESG-enhanced-credit-managed-portfolio.pdf > .

  62. 62.

    Ibid 4.

  63. 63.

    Ibid 5.

  64. 64.

    Figure 3.1 is from the ‘ESG Focus List and Escalation Process’, as included in ibid 6.

  65. 65.

    Figure 3.2 is from the ‘Guidelines for AIIB’s ESG Focus List and Escalation Process’, as annexed to ibid 9.

  66. 66.

    ‘The Policy on the PPM would not apply to the AIIB’s operation of ESG portfolio investments’. AIIB ESF 2021 (n 42) para 14.

  67. 67.

    The story was told by Dong-Ik Lee, an AIIB Director General, in an interview with the online magazine Environmental Finance (n 55).

  68. 68.

    AIIB, ‘Project Summary Information: Infrastructure Private Capital Mobilization Platform’ PD000274 (9 August 2019).

  69. 69.

    This information is found in the project summary of a later project. See AIIB, ‘Project Summary Information: Asia Infrastructure Securitization Program’ P000492 (11 June 2021). The rationale for the derogation from the application of the AIIB ESP is that ‘[t]he ESP is designed for lending to conventional project finance investments and is not ‘fit for purpose’ for capital markets instruments’; see < https://www.aiib.org/en/projects/details/2021/_download/singapore/AIIB-PSI-Asia-Infra-Securitization-Project-vF.pdf > . Bayfront’s ESF can be found at < https://www.bayfront.sg/environmental-social-framework > , and its Sustainable Finance Framework can be found at < https://www.bayfront.sg/sustainable-finance > .

  70. 70.

    AIIB (n 68). Commercial banks and private capital are generally risk averse to infrastructure investment, which features longer maturities and uncertainty. Securitization thus relieves them of such disadvantages, as well as of the stringent capital adequacy requirements for investments involving longer maturities under Basel III.

  71. 71.

    AIIB (n 69).

  72. 72.

    Courtney Lowrance, ‘The Rise of Sustainable Capital Markets’ (AIIB Blog, 12 July 2019) < https://www.aiib.org/en/news-events/media-center/blog/2019/The-Rise-of-Sustainable-Capital-Markets.html > .

  73. 73.

    ‘Greenwashing in Finance: Europe’s Push to Police ESG Investing’ (Financial Times, 10 March 2021); ‘Sustainable Funds Must Work Harder to Vet Their Investments’ (Financial Times, 4 August 2020).

  74. 74.

    For example, in the case of AIIB, an FI project includes ‘medium- to long-term corporate or project finance, lending to small and medium enterprises, trade finance, housing finance and microfinance’. AIIB ESF 2021 (n 42) Vision, para 28. The IFC may invest in a similar FI project; see IFC Sustainability Framework (n 15) Policy on Environmental and Social Sustainability, para 32.

  75. 75.

    G Jokubauskaite et al., ‘The Belgian Investment Company for Developing Countries (BIO) as a Sustainable Development Actor’ (April 2022) 43–53.

  76. 76.

    The accurate name of the UCS in the AIIB ESF is ‘use of country and corporate systems’, which means that both private and public clients may be eligible for the UCS.

  77. 77.

    AIIB ESF 2021 (n 42) ESP, para 54.1.

  78. 78.

    World Bank, ‘Safeguards and Sustainability Policies in a Changing World: An Independent Evaluation of World Bank Group Experience’ (World Bank 2010) 85.

  79. 79.

    Ibid.

  80. 80.

    This counterproductive result is inferred from the interview conducted by the Independent Evaluation Group with World Bank officers. World Bank (n 78) 86.

  81. 81.

    The Eskom Project in South Africa is among the very few recent World Bank projects involving the UCS, and it is one of the largest projects (US$3.75 billion) the World Bank has financed. The project was initiated as a UCS pilot in 2009 and closed in 2021. World Bank, ‘Eskom Investment Support Project’ < https://projects.worldbank.org/en/projects-operations/document-detail/P116410?type=projects > .

  82. 82.

    Similarly, other MDBs that are authorized with the UCS, including the ADB and IDB, have not implemented the authority in investment projects. World Bank, ‘Comparative Review of Multilateral Development Bank Safeguard Systems’ (May 2015) ix, 111.

  83. 83.

    MVC Ormaza and FC Ebert, ‘The World Bank, Human Rights, and Organizational Legitimacy Strategies: The Case of the 2016 Environmental and Social Safeguards’ (2019) 32 Leiden Journal of International Law 487.

  84. 84.

    The World Bank seems satisfied with a relatively soft principle, i.e. the UCS ‘is likely to address the risks and impacts of the project’. However, what difference the wording choices of ‘be likely to’ for the World Bank and ‘adequate’ for the AIIB would make in practice is yet unknown. See IBRD Environmental and Social Framework (ESF) < https://thedocs.worldbank.org/en/doc/837721522762050108-0290022018/original/ESFFramework.pdf > ESP, para 23. AIIB ESF 2021 (n 42) ESP, para 54.1.

  85. 85.

    Dann has commented interestingly that the three criteria in the test of a client system all involve legal and administrative rather than economic performance. This shows that ‘[s]overeignty becomes contingent upon good governance’, and the World Bank eventually becomes the arbiter of sovereignty. P Dann and M Riegner, ‘The World Bank’s Environmental and Social Safeguards and the Evolution of Global Order’ (2019) 32 Leiden Journal of International Law 559.

  86. 86.

    The World Bank used to draft a working methodology as guidance for its project team to make such an assessment, which remained very vague in text, nevertheless. World Bank, ‘Information Note: Assessing the Borrower’s Environmental and Social Framework’ (4 August 2016). It should be noted that the information note’s applicability is yet unknown, given its working draft status as presented on the World Bank website.

  87. 87.

    Parties with such concerns include the US government and a few civil society organizations, as revealed during the consultation phase of the World Bank ESF. World Bank, ‘Review and Update of the World Bank’s Environmental and Social Safeguard Policies Phase 3 Feedback Summary (US)’ (24–26 February 2016).

  88. 88.

    World Bank, ‘Inspection Panel Investigation Report (Report No. 64977-ZA) on South Africa: Eskom Investment Support Project’ (IBRD Loan No. 78620-ZA) (21 November 2011) < https://www.inspectionpanel.org/panel-cases/eskom-investment-support-project > paras 170–194.

  89. 89.

    AIIB ESF 2021 (n 42) Vision, para 13.

  90. 90.

    ‘The Bank, its President, officers and staff shall not interfere in the political affairs of any member, nor shall they be influenced in their decisions by the political character of the member concerned. Only economic considerations shall be relevant to their decisions.’ AIIB AOA (n 3) 31(2).

  91. 91.

    The World Bank’s ESF supports human rights ‘in a manner consistent with its Articles of Agreement’ (IBRD ESF (n 84) Vision, para 3), specifying that the World Bank should make funding decisions with no regard to political or non-economic influences or considerations and should refrain from interfering in the political affairs of members. See IBRD, ‘Articles of Agreement’ < https://www.worldbank.org/en/about/articles-of-agreement/ibrd-articles-of-agreement > art III, Sect. 3.5(b) and art IV, Sect. 10.

  92. 92.

    AIIB ESF 2021 (n 42) Vision, para 13. This interpretation may be inferred from a general encompassing statement at the beginning of the same paragraph, which states that ‘The Bank believes that social development and inclusion are critical for sound development. For the Bank, inclusion means empowering people to participate in and benefit from the development process in a manner consistent with local conditions’; ibid (emphasis added).

  93. 93.

    Jokubauskaite has even commented that ‘[t]he choice of not addressing human rights in the [IBRD] ESF gives more discretion for the borrower to opt for mitigation and compensation measures, rather than trying to ensure more effective prevention of human rights violations’. G Jokubauskaite, ‘The World Bank Environmental and Social Framework in a Wider Realm of Public International Law’ (2019) 32 Leiden Journal of International Law 462 (emphasis in original).

  94. 94.

    A critique of the positioning of human rights in the vision statement is available at European Parliamentary Research Service, ‘Asian Infrastructure Investment Bank: How Lean, Clean and Green is the AIIB?’ (February 2021) 8.

  95. 95.

    Under the AIIB ESF 2021 (n 42), ESS 3 (‘Indigenous Peoples’) states its objective as ‘to design and implement Projects in a way that fosters full respect for Indigenous Peoples’ identity, dignity, [and] human rights’; under the IBRD ESF (n 84), ESS 7 (‘Indigenous Peoples’) states its objective as ‘to ensure that the development process fosters full respect for the human rights’; and under the IFC Sustainability Framework (n 15), Policy on Environmental and Social Sustainability and Performance Standard 1 both recognise ‘the responsibility of business to respect human rights’, and Performance Standard 7 states its objective as ‘to ensure that the development process fosters full respect for the human rights’. Nevertheless, all these are considered to be limited for human rights protection.

  96. 96.

    ‘Use of a Client’s systems (including in situations described in Sect. 61, Adoption by the Client of a Development Partner’s Environmental and Social Policy) does not preclude access of Project-affected people to the Project-level [Grievance Redress Mechanism, or GRM] or to the PPM.’ AIIB ESF 2021 (n 42) ESP, para 59.3.

  97. 97.

    IBRD ESF (n 84) ESP, para 29.

  98. 98.

    Ibid.

  99. 99.

    Dann and Riegner (n 85).

  100. 100.

    This prospect echoes the call of major rising economies, such as Brazil, India and South Africa, during the consultations leading up to the World Bank’s 2016 ESF. It also increases the attraction of the UCS to them. As Jokubauskaite has commented, these economies are probably the main ‘winners’ of the ESF reform. Jokubauskaite (n 93).

  101. 101.

    AIIB ESF 2021 (n 42) ESP, para 54.

  102. 102.

    Ibid ESP, para 55.

  103. 103.

    IBRD ESF (n 84) ESP, para 29.

  104. 104.

    MCDF, ‘Partnering to Advance High-quality Infrastructure and Connectivity’ (2021) 13, 23–25.

  105. 105.

    The AIIB Charter requires the Board of Directors to establish an oversight mechanism to supervise Bank operations (AIIB AOA (n 3) art 26(iv)). The 2016 ESF of the AIIB required the oversight mechanism to be established to receive private complaints over environmental and social harms caused by a Bank-financed project (AIIB ESF 2021 (n 42) ESP, para 64). In December 2018, the PPM was formally established by the Policy on the PPM, the Directive on the PPM and the Rules of Procedure of the PPM, all entering into effect on 31 March 2019.

  106. 106.

    DD Bradlow, ‘International Organizations and Private Complaints: The Case of the World Bank Inspection Panel’ (1994) 34 Virginia Journal of International Law 554.

  107. 107.

    The complex functions may well explain why the Complaints-resolution, Evaluation and Integrity Unit (CEIU), as the administrator of the PPM, changed the meaning of its initial letter C in its name from the original ‘compliance’ (confined to the third function) to the current ‘complaints-resolution’.

  108. 108.

    AIIB Policy on the PPM (n 6) para 2.1.1. The function of ‘project processing queries’, while being similar to the World Bank’s Grievance Redress Service (GRS) in terms of attempting to resolve a private concern promptly, differs in two respects. First, the scope of complaints subject to the GRS is much wider and may well extend any complaint type subject to an Inspection Panel review. Second, the GRS is an internal accountability system, reporting to World Bank senior management, while the PPM, through the Managing Director of the CEIU, reports to the Board. See also World Bank, ‘Grievance Redress Service’ < https://www.worldbank.org/en/projects-operations/products-and-services/grievance-redress-service > .

  109. 109.

    The result may take the form of ‘a time-bound and monitorable dispute resolution agreement or memorandum of understanding’ between the disputing parties, and the PPM is responsible for monitoring its implementation. AIIB, ‘Rules of Procedure of the PPM’ (21 December 2018) < https://www.aiib.org/en/policies-strategies/operational-policies/policy-on-the-project-affected-mechanism.html > (Rules of Procedure of the PPM) para 6.6.

  110. 110.

    Ibid para 6.6.1. By comparison, under the World Bank’s accountability mechanism, the newly added dispute resolution service, as applying between the borrower and a private complainant, does not explicitly deal with any extension to such other stakeholders, though it may do so in practice, upon agreement between the borrower and the complainant. The World Bank Accountability Mechanism (8 September 2020) < https://www.inspectionpanel.org/sites/www.inspectionpanel.org/files/documents/AccountabilityMechanismResolution.pdf > para 9.

  111. 111.

    No other major MDBs merge the three functions, let alone distinguish the ‘project processing queries’ function from others. For example, the IFC’s accountability mechanism, the Compliance Advisor Ombudsman, has the two functions of dispute resolution and compliance, while lacking an explicit mandate of dealing with project processing queries (‘IFC/MIGA Independent Accountability Mechanism (CAO) Policy’ (28 June 2021) paras 62–146). Similarly, the EBRD’s accountability mechanism, the Independent Project Accountability Mechanism, distinctively has two functions of problem solving and compliance; the problem-solving function, by definition ‘supports dialogue between Requesters and Clients to resolve the environmental, social and public disclosure issues underlying a Request, without attributing blame or fault.’ EBRD, ‘Project Accountability Policy’ (April 2019) Section III, para 1.1.a.

  112. 112.

    The limitation on private parties’ freedom of choice is eligibility of submissions (inter alia, parallel pursuit of remedy is disallowed under the Policy on the PPM (n 6) para 5.2.5), plus time limits for filing submissions (Rules of Procedure of the PPM (n 109) paras 4–5). The eligibility requirements, common among the MDBs’ independent accountability mechanisms (IAMs), are quite extensive, a point of criticism concerning the effectiveness of IAMs.

  113. 113.

    The World Bank initiated the first accountability mechanism of the kind among MDBs in 1993, under which the Inspection Panel has since been at the core, and compliance review was its single function until 2020 when the new service ‘dispute resolution’ was added. A succinct description of the establishment of the World Bank accountability mechanism in earlier years can be found in B Gu, The Law and Governance of the Asian Infrastructure Investment Bank (Wolters Kluwer 2019) 129.

  114. 114.

    It means that the dispute resolution service is available only upon authorization of an Inspection Panel investigation. The World Bank Accountability Mechanism (n 110) paras 7, 9 and 11.

  115. 115.

    ‘If the Panel so recommends, the Executive Directors will authorize an investigation without making a judgment on the merits of the claimants’ request’ (The World Bank Inspection Panel Resolution (8 September 2020) para 29). The Board’s exclusive authority to authorize or deny a full investigation led to significant politicization of the Panel process in the initial years; nevertheless, the Board has approved every Panel recommendation for an investigation since the 1999 Clarifications (paragraph 9 of which requiring the Board’s approval). D Hunter, ‘Using the World Bank Inspection Panel to Defend the Interests of Project-affected People’ (2003) 201 Chicago Journal of International Law 206.

  116. 116.

    In exceptional cases of doubt as to whether the technical review criteria have been met, IFC management may request that the Board of Directors review the CAO’s decision to investigate. IFC/MIGA Independent Accountability Mechanism (n 111) para 107.

  117. 117.

    ‘If the PPM decides to recommend approval of the commencement of the Compliance Review or other appropriate course of action, it submits its recommendation to the Board for approval. … If the Board approves a recommendation to commence the Compliance Review ….’ Rules of Procedure of the PPM (n 109) para 6.7.3(d) and (g).

  118. 118.

    The CEIU, a unique unit created within the AIIB, assists the non-resident Board in playing an oversight role to strengthen Bank accountability and effectiveness. The head of the CEIU (i.e. the Managing Director) advises management, while being independent and reporting directly to the Board of Directors. AIIB, ‘Annual Report and Accounts’ (2016) < https://www.aiib.org/en/news-events/annual-report/2016/home/index.html > 9.

  119. 119.

    Rules of Procedure of the PPM (n 109) Attachment 1 ‘Overview of the PPM’ states, inter alia, that ‘[p]roject-specific Task Force members are selected with regard to the nature of the submission and the expertise required’.

  120. 120.

    The Inspection Panel secretariat currently comprises nine devoted staff. For an overview, see < https://www.inspectionpanel.org/about-us/meet-panel > .

  121. 121.

    Although ‘the PPM is assisted by a Secretariat’, as stipulated, the PPM secretariat seems inseparable from the CEIU secretariat because the former is headed by a staff of the latter. Further details about the PPM secretariat are lacking. Rules of Procedure of the PPM (n 109) Attachment 1 ‘Overview of the PPM’.

  122. 122.

    See the description of the Accountability Mechanism Secretary and its secretariat, in The World Bank Accountability Mechanism (n 110) paras 3–5, 10.

  123. 123.

    However, the Accountability Mechanism Secretary indeed plays a certain role with respect to the Inspection Panel, since a dispute resolution service is initiated in the context of the Inspection Panel. The World Bank Accountability Mechanism (n 110) para 8 (c) and (d).

  124. 124.

    The three responsibilities of the CEIU are officially described as follows: For project evaluations, ‘to selectively assess the quality and results (for completed projects) of the Bank’s ongoing and completed portfolio’; for the PPM, ‘to serve as the focal point for external requests or complaints regarding compliance with the AIIB’s ESP under the PPM Policy’; and for business sanctions, ‘to investigate project-related fraud and corruption cases under the Policy on Prohibited Practices’. Terms of Reference for the CEIU (10 July 2019) < https://www.aiib.org/en/about-aiib/governance/_common/_download/toR-for-the-CEIU.pdf > Section A.

  125. 125.

    BY February 2022, the CEIU secretariat had no more than 10 staff, the number of which is expected to increase as Bank operations develop. The head of the CEIU also seems to have gained more importance in the AIIB’s corporate hierarchy, since the position was initially titled Director General, as stated in AIIB, ‘Policy on Prohibited Practices’ (8 December 2016) < https://www.aiib.org/en/policies-strategies/operational-policies/prohibited-practices.html > Sect. 9.2, and has now been renamed and upgraded to Managing Director. Furthermore, potential conflict of interest exists between those mandates, as recognized in the Rules of Procedure of the PPM (n 109) Attachment 1 ‘Overview of the PPM’, paras 7–9.

  126. 126.

    AIIB ESF 2021 (n 42) ESP, para 71. The World Bank requires ‘the Borrower to provide a grievance mechanism, process, or procedure to receive and facilitate resolution of concerns and grievances of project-affected parties arising in connection with the project’. IBRD ESF (n 84) ESP, para 60.

  127. 127.

    AIIB ESF 2021 (n 42) ESP, para 72; Policy on the PPM (n 6) para 2.1.

  128. 128.

    A submission is ineligible if ‘[t]he Requestors have not made good faith efforts to resolve the issues with the Project-level GRM and with Management or have not indicated to the satisfaction of the PPM why they have been unable to do so’ (Policy on the PPM (n 6) para 5.1.8). The key terms here are ‘good faith’ and ‘to the satisfaction of the PPM’, which may refer to such particular reasons as non-functioning of the project-level system or a legitimate fear of retaliation for using the system, as stipulated in Rules of Procedure of the PPM (n 109) para 5.1.8.

  129. 129.

    L Pike, ‘“China’s World Bank” is Making it Easier to Complain’ (China Dialogue, 19 February 2019). K Geary and D Schäfer, ‘The Accountability Deficit: How the Asian Infrastructure Investment Bank’s Complaints Mechanism Falls Short’ (Recourse and Urgewald, October 2021) 16–17.

  130. 130.

    See technical eligibility criteria for a submission under the Inspection Panel procedure: The World Bank Inspection Panel Resolution (8 September 2020) < https://www.inspectionpanel.org/sites/www.inspectionpanel.org/files/documents/InspectionPanelResolution.pdf > paras 13–15, 29.

  131. 131.

    See IBRD ESF (n 84) ESP, para 61; The World Bank Inspection Panel Resolution (n 130) paras 14 and 29(c). These provisions stipulate a technical eligibility criterion of a submission under the Inspection Panel procedure, i.e. ask Bank management first. Admittedly, the criterion is essentially assertion-based and is easy for the complainant to meet.

  132. 132.

    There are two points to note: first, as an exception, the Board of Directors may authorize the PPM to process the complaint; second, the requirement applies to requests for compliance review, irrelevant to project processing queries and requests for dispute resolution. Policy on the PPM (n 6) paras 5.2.4 and 6.8.5.

  133. 133.

    However, critics have argued that the arrangement limits local people’s freedom of choice. Geary and Schäfer (n 129) 19.

  134. 134.

    In practice the PPM has not received a single complaint since its establishment in 2019. While the short existence of the PPM contributes to the status quo, eligibility is a big problem. Among other matters as discussed above, the alternative use of a co-financer’s system is widespread in AIIB-financed projects, resulting in the ineligibility of the majority (72 out of the total 142 projects) for the PPM. Geary and Schäfer (n 129) 5, 11. To be sure, criticism of the accountability mechanism is not unique to the AIIB but is rather common among other IAMs. Another report reviewing 11 IAMs found that the eligibility process gets politicized, and fewer actual investigations have been made over the past 21 years; Center for International Environmental Law, ‘Glass Half Full? The State of Accountability in Development Finance’ (January 2016).

  135. 135.

    M van Putten, Policing the Banks: Accountability Mechanisms for the Financial Sector (McGill-Queen’s University Press 2008) 171, quoting the Basel Committee.

  136. 136.

    For a detailed discussion of the AIIB Board’s oversight power over management, see B Gu and C Xu, ‘International Organizations and Corporate Governance: The Case of the AIIB’ (2022) 30 Asia Pacific Law Review 309.

  137. 137.

    ‘Indigenous peoples shall not be forcibly removed from their lands or territories. No relocation shall take place without the free, prior and informed consent of the indigenous peoples concerned and after agreement on just and fair compensation and, where possible, with the option of return.’ UNGA ‘Declaration on the Rights of Indigenous Peoples’ UN Doc A/RES/61/295 (2 October 2007) art 10 (emphasis added).

  138. 138.

    For example, the EIB and the EBRD both define FPIC as the process whereby the affected community of Indigenous peoples arrives at a decision in accordance with their legal provisions, cultural traditions, customs and practices (World Bank (n 78) 35, 113). The ADB defines consent as ‘a collective expression by the affected Indigenous Peoples communities, through individuals and/or their recognised representatives, of broad community support for the project activities. Such broad community support may exist even if some individuals or groups object to the project activities’ (ADB, ‘Safeguard Policy Statement’ (July 2009) Glossary). The IFC defines FPIC as that which ‘builds on and expands the process of [informed consultation and participation, ICP] and will be established through good faith negotiation between the client and the Affected Communities of Indigenous Peoples.’ IFC (n 15) Performance Standard 7 (‘Indigenous Peoples’), para 12.

  139. 139.

    For example, the ADB holds that the combined requirements of meaningful consultation and broad community support are functionally equivalent to FPIC; and the EIB comments that the only difference between FPIC and ‘free, prior and informed engagement’, a term equivalent to FPICon as a standard for public consultation and participation, is that FPIC is specific to indigenous people as recognized in UNDRIP. World Bank (n 78) 20, 35, 114–115.

  140. 140.

    For example, IBRD ESF (n 84) ESS7, para 23. An elaborate definition of ‘meaningful consultation’ is available in AIIB ESF 2021 (n 42) ESS1, para 23.

  141. 141.

    If there is any significant opposition or major disagreement, it is resolved through good faith negotiations. ADB, ‘Indigenous Peoples Safeguards: A Planning and Implementation Good Practice Sourcebook’ (June 2013) 71.

  142. 142.

    IBRD ESF (n 84) ESS7, para 25(d). AIIB ESF 2021 (n 42) ESP, para 69.2. AIIB President Jin Liqun commented as follows at the AIIB first annual meeting in 2016: ‘Most people are rational; if 99 per cent of local households accept the compensation standard, then the 1 per cent dissenters have to pick up the money and move.’ Quoted in B Gu, ‘AIIB and Changing Standards in China’ (The Straits Times, 28 July 2016).

  143. 143.

    The criteria for establishing FPICon for the AIIB are found in the AIIB ESF 2021 (n 42) ESP, para 69.2, while the criteria for establishing FPIC for the World Bank are found in IBRD ESF (n 84) ESS7, paras 25–26.

  144. 144.

    IFC (n 15) Performance Standard 1, para 32. ‘Informed consultation and participation’ is defined in ibid para 31.

  145. 145.

    Those special circumstances are (i) impacts on lands and natural resources subject to traditional ownership or under customary use; (ii) relocation of Indigenous peoples from lands and natural resources subject to traditional ownership or under customary use; and (iii) where a project may significantly impact on critical cultural heritage; ibid Performance Standard 7, paras 13–17.

  146. 146.

    IFC, ‘Guidance Notes to Performance Standards on Environmental and Social Sustainability’ (1 January 2012) < https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sustainability-at-ifc/publications/publications_policy_gn-2012 > 12.

  147. 147.

    AIIB ESF 2021 (n 42) ESP, para 70.

  148. 148.

    Critics have argued that FPIC is ‘geared towards a negotiation in view of an agreement instead of the quest for an expression of self-determination. It does not allow for indigenous peoples to exercise dissent up front, nor to determine alone their decision-making process and their expression of consent …. FPIC really means “consultation-plus” rather than consent.’ S de Moerloose, ‘Indigenous Peoples’ Free, Prior and Informed Consent (FPIC) and the World Bank Safeguards: Between Norm Emergence and Concept Appropriation’ (2020) 53 World Comparative Law/VRU 237. See another critique of the World Bank’s definition of FPIC in Ormaza and Ebert (n 83).

  149. 149.

    FPICon was originally used in the World Bank’s OP4.10 ‘Indigenous Peoples’, a predecessor to the World Bank’s 2016 ESF.

  150. 150.

    A general criticism of the AIIB’s innovative aspects can be found in Horta and Wang (n 47). The authors mainly advocate for more checks and balances and more transparency for the AIIB.

  151. 151.

    ‘Use of Co-financier’s Independent Accountability Mechanism. If the Project is co-financed with another MDB, bilateral development organization or other development finance institution, and the Bank agrees to the application of the environmental and social policies and procedures of the co-financier (in lieu of the ESP) to the Project, the Bank may also agree to rely on the IAM of such co-financier (in lieu of the PPM) to handle submissions from Project-affected people.’ AIIB ESF 2021 (n 42) ESP, para 73. Instead, the World Bank ESF states merely generally that ‘[w]here the Bank is jointly financing a project with other multilateral or bilateral funding agencies, the Bank will cooperate with such agencies and the Borrower in order to agree on a common approach for the assessment and management of environmental and social risks and impacts of the project’. IBRD ESF (n 84) ESP, para 9.

  152. 152.

    By contrast, in the World Bank Group, only a country may be eligible for the UCS, while a private sector is not, since the IFC does not have a corresponding system in its Sustainability Framework.

  153. 153.

    The governments of Brazil, China, India and South Africa all support and encourage the UCS to be a default choice, subject to the requirement of ‘material consistency’, as evidenced during the consultation phase leading up to the 2016 ESF of the World Bank.

  154. 154.

    ‘Use of a Client’s systems … does not preclude access of Project-affected people to the Project-level GRM or to the PPM.’ AIIB ESF 2021 (n 42) ESP, para 59.3.

  155. 155.

    Featuring a rethinking of law and governance for effectiveness of development policies, the World Bank departs from its long-held manifesto, calling on the development community to think and do development differently from traditional technocratic approaches, and specifically to ‘think not only about the form of institutions, but also about their functions; think not only about capacity building, but also about power asymmetries; think not only about the rule of law, but also about the role of law’. World Bank, ‘World Development Report 2017: Governance and the Law’ (2017) <https://www.worldbank.org/en/publication/wdr2017> 29, 71 and 279.

  156. 156.

    While the safeguard systems demonstrate regulatory convergence across the MDBs, there are nuanced differences in many specific provisions. Specifically, discrepancies in the social sector seem even more significant than in the environmental sector, particularly with respect to the protection of human rights and Indigenous peoples’ rights. On regulatory convergence and discrepancy across the MDBs’ safeguards, see M Mbengue and S de Moerloose, ‘Multilateral Development Banks and Sustainable Development: On Emulation, Fragmentation and a Common Law of Sustainable Development’ (2017) 10 Law and Development Review 404.

Author information

Authors and Affiliations

  1. School of Law, Beijing Foreign Studies University, Beijing, China

    Bin Gu

Authors
  1. Bin Gu
    View author publications

    You can also search for this author in PubMed Google Scholar

Corresponding author

Correspondence to Bin Gu .

Rights and permissions

Reprints and permissions

Copyright information

© 2024 The Author(s), under exclusive license to Springer Nature Singapore Pte Ltd.

About this chapter

Check for updates. Verify currency and authenticity via CrossMark

Cite this chapter

Gu, B. (2024). Operational Standards: Environmental and Social Framework 2021. In: Chinese Multilateralism in the Asian Infrastructure Investment Bank (AIIB). Modern China and International Economic Law. Springer, Singapore. https://doi.org/10.1007/978-981-97-1219-9_3

Download citation

  • DOI: https://doi.org/10.1007/978-981-97-1219-9_3

  • Published:

  • Publisher Name: Springer, Singapore

  • Print ISBN: 978-981-97-1218-2

  • Online ISBN: 978-981-97-1219-9

  • eBook Packages: Law and CriminologyLaw and Criminology (R0)

Publish with us

Policies and ethics

Search

Navigation