Extractive Industries and Development Series #31 May 2016 Integrating Social Accountability Approaches into Extractive Industries Projects: A Guidance Note Katherine Heller Warren van Wicklin III Saki Kumagai with Michael Jarvis Sanjay Agarwal Theodore Dreger May 2016 Integrating Social Accountability Approaches into Extractive Industries Projects A Guidance Note Table of Contents Acknowledgments v List of Acronyms vi Introduction 1 What Is Social Accountability, and How Does It Relate to the Extractive Industries? 2 Why Social Accountability Matters to Extractive Industry Operations 6 Steps in Integrating Social Accountability into Project Design and Implementation 8 Step 1: Identifying and Prioritizing Social Accountability Concerns and Opportunities 9 Step 2: Understanding Context and the Enabling Environment 10 Step 3: Select Social Accountability Tools and Methods 12 Step 4: Decide on Implementation Modalities 12 Step 5: Monitoring and Evaluation 14 Sustaining and Scaling Up Social Accountability Activities 17 Incorporating Gender into Social Accountability Activities 18 The Extractive Industries Transparency Initiative 20 Integrating Social Accountability Activities along the Extractive Industry Value Chain 25 Link 1: Award of Contracts and Licenses 26 Link 2: Regulation and Monitoring of Operations 33 Link 3: Collection of Taxes and Royalties 38 Link 4: Revenue Management and Allocation 41 Link 5: Implementation of Sustainable Development Policies and Projects 49 I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s iii Conclusion 57 References 58 Annex 1. Checklist for Designing and Implementing Social Accountability Activities 62 Annex 2: Sample Indicators for Social Accountability 64 Annex 3. Sources of Information on Social Accountability in Extractive Industries 66 World Bank Resources 66 External Resources 66 iv Integrating Social Accountability Approaches into EI Projects Acknowledgments This paper was developed as a collaboration between the World Bank’s Oil, Gas, and Mining team of the Energy and Extractives Global Practice (GEEDR), the former World Bank Institute, and the World Bank Governance Practice. The team was led by Katherine Heller (GEEX2, Task Team Leader), with Warren van Wicklin III, Saki Kumagai, Michael Jarvis, Sanjay Agarwal, and Ted Dreger. The team would like to thank Paulo de Sa (Sector Manager, Oil, Gas, and Mining team), as well as Kristina Svensson, Ousmane Deme, Helene Grandvoinnet, Carey Hairston Kluttz, Jen Scott, Karla Diaz Clarke, and Fernando Ruiz Mier, as well as Isabel Munilla from Oxfam American, and Caroline Rusten, for their invaluable contributions. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s v List of Acronyms ACIDH Action against Impunity for Human Rights ALAC Asociación Los Andes de Cajamarca ANSA-EAP Affiliated Network on Social Accountability—East Asia and Pacific Region ASM artisanal and small miners AusAID Australian Agency for International Development BTC Baku-Tbilisi-Ceyhan CBO community-based organization CDA community development agreement CDF community development fund CMU Country Management Unit COICA Coordinadora Indígena de la Cuenca Amazónica CSA country social analysis CSO civil society organization CTPD Center for Trade, Policy and Development DACDF Diamond Area Community Development Fund DRC Democratic Republic of the Congo ECZ Environmental Council of Zambia EI extractive industry EIA environmental impact assessment EITI Extractive Industries Transparency Initiative ESIA environmental and social impact assessment GIS geographic information system IAG international advisory group IAP international advisory panel IFC International Finance Corporation IMF International Monetary Fund IPF investment project financing vi Integrating Social Accountability Approaches into EI Projects IT information technology J4P Justice for the Poor M&E monitoring and evaluation MDTF multi-donor trust fund MIM independent monitoring mechanism NGO nongovernmental organizations NRGI National Resource Governance Institute (formerly RWI) OGP Open Government Partnership OPSPQ Operational Policy and Quality Department ORAF operational risk assessment framework ORCADE Organisation pour le Renforcement des Capacités de Développement (French) PDO project development objective PDR People’s Democratic Republic PEA political and economic analysis PLNG Peru Liquefied Natural Gas POM Platform of Civil Society Organizations Working in the Mining Sector PSIA poverty and social impact analysis PWYP Publish What You Pay RAJIT le Réseau Africain de Journalistes pour l’Intégrité et la Transparence (French) RTI right to information RWI Revenue Watch Institute SA social accountability SESA strategic environmental and social assessment SORT Systematic Operations Risk-Rating Tool TAP transparency, accountability, and participation TTL task team leader USAID United States Agency for International Development WBG World Bank Group WBI World Bank Institute I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s vii Introduction This note provides guidance on how to use social accountability (SA) approaches in oil, gas, and mining projects, with particular emphasis on World Bank projects in the extractive industry (EI) sectors. It highlights some consequences of poor trans- parency and accountability in EI sectors and identifies opportunities for addressing these issues. It demonstrates how the use of SA approaches and tools can improve the implementation and outcomes of EI projects. Although the note is written primar- ily for a World Bank/International Finance Corporation (IFC) audience and project cycle, it is hoped that it will be a resource for government, industry, and civil society partners as well.1 Social accountability has gained increasing importance in the World Bank’s work over the past two decades. Development partners—including governments, industry, and citizens—recognize the critical role of citizen voice and participation in improv- ing governance. In turn, this can reduce project risk and create more sustainable development outcomes. Particularly in countries with developed or potential mineral wealth, transparency, accountability, and citizen participation are key factors in how those resources contribute to growth and poverty reduction. The increasing use of information technology (IT) has accelerated and broadened the range of stakehold- ers, especially civil society organizations (CSOs), which are adopting SA approaches to improve transparency, accountability, and participation in EI sectors. Section 2 provides definitions of social accountability and citizen engagement, and the relationship between the two. It lists some common tools and approaches to SA. Section 3 explains how SA can both improve the implementation and outcomes of EI projects as well as reduce problems and negative outcomes. Section 4 outlines step- by-step guidance on the design, implementation, monitoring and evaluation, and sustaining of SA activities. It also provides suggestions on how to incorporate gender into SA activities. Section 5 describes how the Extractive Industries Transparency Initiative (EITI) can serve as a platform for SA approaches. Section 6 discusses the opportunities and challenges for SA for all five links of the EI value chain, identifies entry points for SA, and provides suggestions and examples of how SA approaches and tools can be used to address specific challenges in EI projects. The annexes list additional sources of information on using SA approaches in EI projects, including a checklist and suggested SA indicators. 1  enerally, the note is most applicable to investment lending projects in the oil, gas, and mining sector, but different elements of the note G are relevant to different types of projects. At least parts of the note are applicable to a wide range of projects and stakeholders, not just World Bank task teams. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 1 What Is Social Accountability, and How Does It Relate to the Extractive Industries? Social accountability substantially overlaps with citizen engagement. This note first defines citizen engagement and then social accountability. • Citizen engagement is defined by the World Bank (2014a) as the two-way inter- action between citizens and governments or the private sector within the scope of World Bank Group interventions—policy dialogue, programs, projects, and advisory services and analytics—that gives citizens a stake in decision mak- ing with the objective of improving the intermediate and final development outcomes of the intervention.2 The spectrum of citizen engagement includes consultation, collaboration, and empowerment. Four aspects of civil society engagement, moving from the weakest to the strongest level of participation, are as follows: a. Inform—providing citizens with objective information to assist them in understanding the problem, alternatives, opportunities, and solutions b. Consult—obtaining citizen feedback on analysis, alternatives, and decisions c. Collaborate—partnering with citizens in parts or all of decision making d. Empower—final decision making is in the hands of citizens Although many forms of outreach and transparency are important elements of citizen engagement, it’s worth noting that access to information, for example, typically implies a one-way interaction only. Information-sharing and awareness- raising activities alone, therefore, do not meet the World Bank’s definition of citizen engagement. Closing the feedback loop (i.e., a two-way interaction pro- viding a tangible response to citizen feedback) is required to effectively use their input to facilitate improved development outcomes, to meet citizens’ expecta- tions for change triggered by their engagement, and to justify the cost of engag- ing with them.  his definition is from the World Bank’s Strategic Framework for Mainstreaming Citizen Engagement in World Bank Group Operations: T 2 Engaging with Citizens for Improved Results (2014a, p. 8). This is the main document outlining the World Bank’s approach to citizen engagement. Citizens are all the people in a country or society, and the term citizens does not refer to their legal status. 2 Integrating Social Accountability Approaches into EI Projects • Beneficiary feedback is a subset of citizen engagement that is applicable to World Bank investment project financing. It refers to citizen engagement with those citizens who are clearly identifiable (direct) project beneficiaries during invest- ment project financing (IPF) preparation, implementation, and evaluation. Securing beneficiary feedback is a critical component of citizen engagement and a key aspect of ensuring that projects understand, respect, and respond to the needs and views of the people they impact. A number of mechanisms exist for engaging with citizens. They broadly include (a) consultation and feedback mechanisms, such as focus groups and satisfaction surveys; (b) collaborative mechanisms, such as participatory planning and budgeting; and (c) citizen-led mechanisms, such as community management or user manage- ment committees. In addition, third-party monitoring mechanisms include social audits, citizen report cards, community scorecards, and public expenditure tracking surveys. Social accountability refers to the broad range of actions and mechanisms beyond voting that citizens can use to hold the state accountable, as well as actions on the part of government, civil society, media, and other societal actors that promote or facili- tate these efforts.3 Social accountability approaches are based on three key principles: transparency, accountability, and participation (the TAP principles). • Transparency refers to the availability and accessibility of information to the general public, along with clarity about government rules, regulations, and decisions. Information must be understandable and communicated to the gen- eral public so that it can be acted upon. This is the foundation upon which the other two TAP principles, accountability and participation, are built. Transparency, therefore, is a necessary, but not sufficient, condition for social accountability. • Accountability can be defined as the obligations of individual or institutional power-holders, at national and local levels, to take responsibility and account for their actions. Two main components of accountability are answerability and power to sanction. • Participation is the critical link between transparency and accountability. Whereas transparency refers to information being made available and acces- sible, accountability refers to the fact that people can practically and legiti- mately be held responsible for that information; neither the information nor that accountability are meaningful unless citizens can participate and effec- tively use this information to hold governments, service providers, companies, and CSOs representing citizen interests accountable. Participation can take many forms and ranges from simple consultations to giving citizens the authority to influence budgetary or service-delivery decisions. Participa- tion should be rigorous, high quality, and gender sensitive and have a demonstrable 3  See Malena and McNeil (2010). I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 3 impact on outcomes. Some SA interventions focus only on transparency, that is, working to make information available and accessible. Others focus on ensuring that there are forums and mechanisms to facilitate demands for accountability. But with- out encouragement and protection for participation, the effectiveness of transparency and accountability to lead to changes in governance will be limited. All three prin- ciples are critical to improve governance and development outcomes. Table 1 lists several examples of typical activities for achieving each of the three SA principles.4 Box 1 describes the Social Accountability E-Guide, which provides several pages of information on many SA tools, how to integrate them into projects, and much more. Table 1: Tools Supporting Each of the Key Pillars of Social Accountability (TAP) Transparency Accountability Participation Information Monitoring Participatory Decision Dissemination and • Third-party monitoring Making Demystification • Participatory monitoring • Participatory policy • Public disclosure of • Community scorecard making information • Independent oversight • Participatory planning • Information-sharing • Public expenditure • Participatory budgeting and awareness-raising tracking • Consultations with campaigns • Input tracking feedback • Access-to-information • Citizen/user laws Complaint Handling membership in decision- • Open-data activities • Grievance redress making bodies mechanism • Community management Box 1: Online Tool to Assist Task Teams: Social Accountability E-Guide This is an online resource that aims at increasing knowledge and under- standing of key SA approaches and tools and helps task teams make informed decisions in selecting appropriate SA mechanisms to strengthen the results of their project and programs. It provides step-by-step guid- ance to task teams, from the scoping and identification of entry points, to sequencing, implementation, and monitoring and evaluation of SA activities. It also provides case examples. It is publicly available at https:// saeguide.worldbank.org/.  or a glossary of these SA tools and approaches, see World Bank (2011d, pp. 20–21). For a more detailed description, see the Social F 4 Accountability E-Guide (described in Box 1) at https://saeguide.worldbank.org/. 4 Integrating Social Accountability Approaches into EI Projects Although there is no formal World Bank definition of the relationship between social accountability and citizen engagement, for the purposes of this note, SA is primarily activities whose objectives are to hold the state accountable. The set of SA tools in Table 1 is almost identical to the list of citizen engagement mechanisms previously described: both use the same tools. However, because the World Bank definition of citizen engagement does not include information-sharing and awareness-raising activities, the transparency set of SA activities is not considered citizen engagement by the World Bank. Therefore, SA is more accurately seen as overlapping with citizen engagement, but not entirely a subset of citizen engagement. Furthermore, in the EI context, another important distinction is that many SA activities are aimed at the private-sector companies that undertake most EI exploration and production activities. This often requires a tripartite approach between governments, the private sector, and citizens. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 5 Why Social Accountability Matters to Extractive Industry Operations Social accountability in the EI sectors entails providing citizens the opportunity to be engaged at the various stages of the EI value chain. This includes establishing trans- parent contracting processes that allow for the public to monitor and challenge the contracts, the payment of royalties and taxes, revenue allocation, and management processes, as well as participating in monitoring of environmental and social impacts and helping to make EI project development impacts more sustainable. Social accountability relates not only to how government services are administered and delivered, but also to how revenue generated from natural resources by extrac- tive industries are contributing to national, regional, and local development. Social accountability empowers and facilitates citizens to ask such questions as “How much government revenue is generated by the oil, gas, and mining sectors?” and “What is it being spent on?” Although governance mechanisms in the extractive industries, such as the EITI, work to make information available, SA goes beyond this to create meaningful opportunities for people to use information to hold government and service providers accountable. Furthermore, governments are not the only main actors. Although governments reg- ulate the industry, the private companies conducting EI operations also have social or legal contracts, bound by local laws or their own codes of conduct. Civil society’s ability to hold companies responsible for these obligations and to ensure that govern- ment is doing its part to require adherence is vital to independent accountability and good governance. Although SA can provide many benefits, the costs, risks, and difficulty of SA should not be underestimated. The time and human and financial resources required for SA activities can be significant. The costs tend to be up front, whereas the benefits usually take much longer to materialize. Despite the upfront costs, SA can be cost- effective over the long run because it helps the project achieve sustainable develop- ment outcomes. SA has risks. Because it is political, it can create tensions between citizens and officials. SA can increase expectations that cannot be met. It can have unintended impacts if 6 Integrating Social Accountability Approaches into EI Projects it unfairly gives greater voice to stakeholders better able to participate than to those who represent the interests of the majority. Elite capture, nepotism, patronage, and other abuses have plagued SA where more powerful and better connected stakehold- ers use it to promote their private interests. SA may have limited impact if governments or companies are not interested in—or actively opposed to—increased transparency, accountability, and participation. There is a risk that projects will apply SA superficially, without sufficient due diligence and rigor for ensuring accountability. There is a need to go beyond “checking the box” toward a longer-term focus on bottom-up citizen participation and engagement as an intrinsic, not just an instrumental, development goal. People need incentives to participate, and if they think the impact of their participation is not worth the effort, they are unlikely to participate. Even when SA is not risky, costly, or poor quality, there are limits to what it can achieve or where it can be effective. It may not be as effective when governments lack the capacity or financial means to sustain improvements, even if they are responsive. Observers may conclude that SA does not work, and this may undermine its prin- ciples even when the problem is ineffective application. Even when SA is effective, its approach may not be sustained, especially if supported by external funding. The three- to five-year project approach is not well suited for SA, which can require longer gestation periods for visible results. Institutionalizing and sustaining SA may turn out to be difficult and complex. Despite these costs and risks, SA can be important in EI operations. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 7 Steps in Integrating Social Accountability into Project Design and Implementation This section explores the key considerations for design and implementation of SA approaches in World Bank projects, including EI projects. There are five key steps for integrating SA into project design and implementation: Step 1: Identify and prioritize social accountability concerns and opportunities. Step 2: Assess the political, legal, and social context for social accountability. Step 3: Select social accountability activities according to the context. Step 4: Decide on implementation modalities for social accountability activities. Step 5: Monitor and evaluate social accountability activities. The World Bank has developed several resources that summarize key actions for each of these steps. Each of the five steps is presented in much more detail in the World Bank Social Accountability E-Guide. Annex 1 contains a checklist summarizing the key actions under each of these five steps. More information can also be found in World Bank’s How-To Note “How, When, and Why to Use Demand-Side Gover- nance Approaches in Projects,” which provides steps for integrating SA into World Bank projects.5 To support integration of these activities into the World Bank project cycle, Table 2 overlays these steps onto the World Bank project cycle to provide an overview of the key tasks for integrating SA at each stage of project design and implementation. For a detailed discussion of these steps, see World Bank (2011d, pp. 5–18), and World Bank (2013, pp. 7–19).  5 8 Integrating Social Accountability Approaches into EI Projects Table 2: Integrating Social Accountability into the Project Cycle Project stage Tasks Project Concept • Diagnose the context for social accountability. Note • Explore the relevance of social accountability approaches to address governance issues and risks. • Develop government, company, and other stakeholder buy-in. Design and • Design project and select social accountability strategy and Preparation methods. • Identify and engage the key stakeholders who will lead social accountability initiatives. • Analyze proposed social accountability activities: risks, impacts, costs, and benefits. Quality • Prepare social accountability initiatives, including the project’s Enhancement disclosure strategy. Review • Estimate costs and resources needed to prepare and supervise social accountability measures. Appraisal • Appoint focal points for managing social accountability activities. • Integrate social accountability mechanisms into the operations manual, results framework, etc. • Initiate planning and mobilization for rollout of social accountability activities. Implementation • Ensure that implementation of social accountability activities Support follows the design. • Ensure that findings from SA activities are being followed up and inform project management. • Record social accountability-related indicators in Implementation Status and Results Report. Evaluation • Assess the impact of social accountability initiatives. • Report on specific intermediate and outcome SA indicators in the assessment. Step 1: Identifying and Prioritizing Social Accountability Concerns and Opportunities The first step in any SA approach is to identify governance opportunities and con- cerns, then prioritize potential issues and activities. It is important to be strategic and problem-driven in identifying the measures that will be supported. To identify opportunities for potential social accountability activities, task team leaders (TTLs) should (i) map key project activities and objectives, and (ii) identify governance concerns and opportunities associated with the project. This can identify potential accountability entry points. Although SA is more about improving project out- comes than about avoiding or mitigating risks, identifying entry points through the I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 9 Systematic Operations Risk-Rating Tool (SORT) or other risk assessment methods can be useful.6 Step 2: Understanding Context and the Enabling Environment The sociopolitical context influences both the potential for SA activities to effect change and the type of SA approach that may be most effective, depending on the capacity, trust, and strength of the legal and regulatory framework. Key factors in assessing the social, political, and legal contexts for SA include the following: • Incentives: What incentives do government, industry, and civil society have to use SA approaches? • Accountability mechanisms: What are the mechanisms by which civil society can hold government accountable? Do these already exist, or will these need to be developed? • Level of institutional capacity: To what extent do institutions exist through which civil society can demand accountability? Are they sufficiently specialized and decentralized? • Inclusiveness: How are women, ethnic minorities, the poor, and other vulner- able or marginalized groups able to influence decisions? • Access to information: Does an access-to-information (ATI) law exist? To what extent are citizens able to access information on government and compa- nies’ operations? • Media and journalist capacity: How effective is the media in interpreting, analyzing, and disseminating information? • Relationship between state, civil society, and industry: The history of this relationship can be a major constraint to, or foundation for, SA activities. One important indicator of the context for SA in the EI sector is its status on compli- ance with the EITI Standard. That provides valuable information on who is engaged on EI issues, the state of relationships between various stakeholders, key issues, and so on. For other issues—such as consultation, compensation, land rights, and other community concerns—other tools are necessary. The World Bank offers various tools that can be used to understand the context for transparency and accountability while planning a project. These include: • Poverty and social impact analysis (PSIA) • Environmental and social impact assessment (ESIA)  or how to identify entry points for SA using the operational risk assessment framework (ORAF), see World Bank (2012d). Although the F 6 ORAF has been replaced by the SORT within the World Bank, most of the social accountability approaches to risk management are still relevant. 10 Integrating Social Accountability Approaches into EI Projects • Strategic environmental and social assessments (SESA) • Country social analysis (CSA) or political and economic analysis (PEA) These analyses should be conducted prior to project implementation, but also at rel- evant moments in each country’s political context, for example, in the consideration of a new mining law or regulation.7 Upfront analysis of these contextual issues will help improve project design. Box 2 describes two examples of strategic assessments that recommended SA activities to address governance issues in EI sectors. Box 2: Examples of Strategic Assessments of the Extractive Industries Recommending Social Accountability Activities Angola—Oil, Broad-Based Growth, and Equity (January 2007): Addressing governance and transparency issues was one of the four main reform areas of this country social analysis. Its recommendations included: (i) engage civil society in revenue management and a transparency pro- cess; (ii) organize workshops to include civil society; (iii) establish an inde- pendent public information center; (iv) develop a time-bound, funded action plan for implementation of transparency agenda; (v) achieve formal endorsement of the EITI and agreement on an action plan for its imple- mentation; (vi) develop a more accessible, user-friendly website for oil data; and (vii) develop a clearer strategy to manage the country’s growing oil and diamond wealth based on sound governance and transparency principles. Sierra Leone Mining Sector Reform: A Strategic Environmental and Social Assessment (SESA) (June 2007): This SESA was undertaken to assist the government in developing its minerals policy. Stakeholder and political economy analysis of mining-sector reform led to stakeholder prioritization workshops. These generated recommendations, including: (i) establish a monitoring framework that provides clear roles for participa- tion by local governments, civil society, and nongovernmental organizations (NGOs); (ii) require ESIAs to be presented in a manner that is understand- able to local community representatives, mediators, and the judiciary and that clearly identifies the legal obligations and commitments of mining companies; (iii) develop an easily accessible system of dispute resolution in the mining sector; (iv) include in the mining law a framework for consul- tation and negotiations on local development for mining operations; and (v) establish mechanisms to enhance women’s access to mineral resources and their involvement in discussions and negotiations with mining compa- nies, including the promotion of greater participation in local government.  When such changes in law and regulations are supported by the World Bank’s operation and likely to have significant poverty and social 7 consequences, analysis of poverty and social implications are required by OP 8.60. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 11 Step 3: Select Social Accountability Tools and Methods The third step in integrating SA approaches into projects is selecting the tools and methods. Figure 1 (on page 25) categorizes some of the most prominent SA tools in terms of their principal objective: enhancing transparency, accountability, or partici- pation. Other major considerations in the selection process include (a) the extent to which a given initiative is dependent on government cooperation, (b) the complexity or difficulty of implementing the SA activity, (c) stakeholder capacity and experience with the tool or method, and (d) cost and time considerations. Table 3 (on page 13) shows four categories of citizens’ concerns and how SA approaches and tools can help address these concerns. Based on the considerations in Table 3, the next steps are to: (a) identify a SA strat- egy or approach that might be a good fit for the context and governance challenge, (b) conduct a brief diagnostic, (c) review some of the main characteristics of the SA approach being considered to see how they fit with the diagnostic, (d) select the best SA approach and who will implement it through a consultative process, and (e) develop a first-cut strategy. Selecting the strategy is not a one-time task, but an ongoing, iterative process with learning and adaptation along the way. Key stages of designing and implementing SA activities include the following: • Begin preparation and early risk assessment. • Validate initial design. • Pilot field methods, monitor and adjust methods. • Expand after pilot testing. • Implement and document SA initiative. • Validate findings with stakeholders. Step 4: Decide on Implementation Modalities The fourth step is to decide the details for implementing selected SA activities. Although it may be evident in most projects where they need to be introduced, in some cases, project teams may need to rely on SA specialists to identify synergies with existing project components for optimal cost-effectiveness and impact. Specialists are especially useful in understanding the implications of the context for the choice and integration of tools and conceptualizing the big picture, such as selecting and sequencing tools, linking them to project activities, and planning for institutional- izing and scaling up SA. Selecting partners: Social accountability activities are dependent on selecting capable partners for implementation. Citizens often lack the skills to undertake many of the challenging tasks in EI; they need training, organizing, and support. Possible partners for the implementation of SA tools include CSOs (international, national, or local organizations and coalitions), private firms (especially consulting firms), universities, 12 Integrating Social Accountability Approaches into EI Projects Table 3: Sample Social Accountability Tools to Address Different Citizen Concerns How Social Accountability Citizen Concern Can Help Sample Tools • Lack of information about EI • Increase transparency • Public disclosure of projects and impacts and access to information • Lack of information about EI information • Public displays of contracts, license procedures, • Make information information collection of royalties and taxes, more understandable to • Information campaigns and revenues and how they are people • Budget literacy allocated campaigns • Lack of information about local procurement, local sourcing opportunities, or hiring by extractives operators • Complaints about EI operations, • Provide people assistance • Grievance redress especially their negative impacts in seeking redress mechanism • Public hearings • Citizens’ juries • Weak monitoring of EI operations • Establish independent, • Third-party monitoring • Limited oversight of how EI civil society, or • Participatory monitoring revenues are collected and allocated community monitoring • Community scorecard • Weak legal framework for • Integrate citizen • Consultation with civil collection of taxes and royalties concerns into EI society and communities • Weak regulation of EI operations regulations and policies • Citizen participation in • Develop legal decision-making bodies frameworks to regulate EI operations • EI regulations do not sufficiently • Organize people to • Citizen participation in protect impacted communities and protect their interests decision-making bodies their interests through committees, • Participatory planning • People are not sufficiently CSOs, and community- • Participatory budgeting involved in decisions on EI based organizations revenue allocation, community (CBOs) development agreements, etc. • Invite citizen • Skepticism that benefits of EI and community operations are adequately shared participation in EI with impacted communities decision making and • Lack of EI company accountability policy setting to citizens and communities and other research institutions. Partners need to have experience in working with communities and groups that often are marginalized, such as women. The skills required for specific activities are likely to be a primary criteria in selecting partners. The selection of capable partners is critical not only for the effective implementation of the project, but also for the credibility of fairness toward the project itself. The partner institutions that hold government and service providers accountable should also be held accountable to beneficiaries they are representing. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 13 Generating Buy-In: Social accountability activities are often seen by governments as an unwelcome degree of oversight, or as limiting their discretion. Greater transpar- ency and accountability regarding how licenses and contracts are awarded, royalties and taxes are calculated, and EI revenues are allocated and managed can often be per- ceived as an unwelcome intrusion. Therefore, it can be useful to address government concerns and highlight how SA tools make certain aspects of government responsi- bility easier and less contentious and can result in improved outcomes. For example, transparency about EI licenses, contracts, regulations, royalties, taxes, and revenue allocation can provide public officials the opportunity to demonstrate responsive- ness and improved outcomes. In this way, SA can improve government–citizen rela- tionships. SA tools that are used to monitor environmental impacts, the delivery of benefits to local communities, adherence to regulations, and so on can appeal to higher-level officials. Communities can provide more detailed and accurate informa- tion, and can create a shared sense of ownership and responsibility. The caveat is that responsibility is often transferred to local communities without resources and sup- port commensurate to the tasks communities are expected to carry out. Capacity: Social accountability activities usually require some initial investment for training and technical support. It is important to find means to support such activi- ties in the future without external funding. For example, although an initial par- ticipatory monitoring activity may require training, the objective would be to create a mechanism that is appealing and easy enough to manage that communities can maintain SA without external funding. Step 5: Monitoring and Evaluation Monitoring and evaluation (M&E) of SA interventions is essential for understanding and evaluating their impacts, and adjusting the design of programs for maximum benefit. Project design can better integrate M&E by defining a theory of change to understand the logic of the SA intervention, setting up systems to capture infor- mation during implementation, establishing an M&E unit to coordinate all M&E activities, and agreeing on the M&E plan and indicators with all the relevant stake- holders. This can be supported by including an M&E specialist from the beginning of the project. Typical key questions include: • Are people acting on information made available? • Which information do they use, and how do they use it? • What channels are they using to make their voices heard? • Is the company/government responding to citizen concerns? It is necessary to establish the main objectives of the SA activity to identify the types of change required to achieve project objectives. This may be conducted as part of a needs assessment or a political economy or contextual analysis. Such objectives can include project development objectives (PDOs) that explicitly support transparency (e.g., publication of revenues) and monitoring mechanisms that go beyond transpar- ency to capture improved participation in decision making around mining, or that 14 Integrating Social Accountability Approaches into EI Projects include SA-related indicators as part of M&E systems. Two examples from EI proj- ects are described in Box 3. Box 3: Examples of Extractive Industry Project PDOs That Incorporate Social Accountability • Ghana Gas and Oil Capacity Building Project: To improve public management and regulatory capacity while enhancing transparency. Four sets of activities focused on increasing transparency and accountability in the oil and gas sector were instituted: (a) strengthening the capacity of public agencies involved governance in the oil and gas sector, for commu- nication, outreach, and dissemination of information; (b) strengthening sector governance by establishing an independent information resource center on oil and gas; (c) building the capacity of the secretariat support- ing the EITI in the oil and gas sector; and (d) strengthening informa- tion and accountability mechanisms at the local level and anticorruption functions at the national level. • Democratic Republic of the Congo (DRC) Growth with Governance in the Mineral Sector Technical Assistance Project: To strengthen institutional capacity to manage the sector in an efficient, accountable, and transparent manner. The project will support activities intended to: (i) develop, improve, and support transparency and monitoring mecha- nisms regarding trade, sector management, and revenues (e.g., the ongo- ing EITI process); (ii) promote awareness regarding the fiscal regime and tax collection mechanisms; and (iii) set up a broad multiple-stakeholder accountability and dialogue platform for mining. Increasingly, projects are explicitly including SA approaches in their project out- comes and indicators, in turn encouraging task teams to ensure that SA activities are part of project implementation. Indicators are concrete, specific descriptions of what TTLs will measure. Overall, indicators should be specific, measurable, achiev- able, relevant, time-bound (SMART). Both quantitative and qualitative indicators are important to capture the critical behavioral changes. Three examples from EI projects are described in Box 4. Annex 2 contains examples of process and outcome indicators for information dissemination, grievance redress, consultation, empower- ment, beneficiary feedback, and M&E activities—the main types of SA activities.8 When designing a SA component or activity, TTLs can use logical frameworks (log- frames) to articulate the logic of the intervention and the expected results from a particular intervention. Logframes typically include five elements: inputs, processes, outputs, outcomes, and impacts. They are established via four key steps: (i) identify the expected change and outcomes, (ii) develop indicators, (iii) identify data sources and collection methods, and (iv) analyze data.  The social accountability e-guide (https://saeguide.worldbank.org/) contains numerous examples and advice on SA indicators under Step 5, 8 monitoring and evaluation. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 15 Box 4: Examples of Project Outcome and Intermediate Outcome Indicators That Incorporate Social Accountability • Ghana Gas and Oil Capacity Building Project: Outcome indicator: Oil and gas contracts made available to the public. Intermediate out- come indicators: (i) regular communication from public sector to public officials and citizens on oil and gas issues, and (ii) number of users per month of the Independent Information Resource Centre. • Tanzania Sustainable Management of Mineral Resources Project: Outcome indicator: Percentage of citizens in participating communities who consider that their views have been taken into account in the local economic development strategic planning process. Intermediate outcome indicators: (i) Legal and regulatory framework for the mining sector that is modern and transparent is disseminated, (ii) specific environmental and social policies and guidelines (mine closure, mercury) are developed, and (iii) percentage of public satisfaction with the mining sector is measured (by a survey). • DRC Growth with Governance in the Mineral Sector Technical Assis- tance Project: Outcome indicator: Status of transparency and account- ability mechanisms. Intermediate outcome indicators: (i) production of EITI reconciliation reports for increased transparency of mining sector, and (ii) monitoring of social and environmental impacts of industrial mining activities involving the participation of local communities. Social accountability indicators have become more important since the World Bank launched its citizen engagement initiative in 2014. The World Bank’s Operational Policy and Quality Department (OPSPQ) has developed guidance on investment project financing preparation, including the results framework and M&E.9 This guidance encourages citizen engagement in project preparation where relevant. The World Bank has set a goal to include beneficiary feedback in all projects where ben- eficiaries are clearly identified by FY18—defined as citizen engagement in all IPFs. Practically all SA activities and indicators, except for most transparency and informa- tion dissemination activities, qualify as citizen engagement according to the OPSPQ definition. Task teams should work with borrowers to: • include at least one citizen engagement indicator in the results framework of the PAD; and • begin reporting on at least one citizen engagement indicator (or demonstrate that credible progress has been made toward reporting on the indicator) in ISRs and aide memoires as soon as practicable and relevant after project effectiveness.  World Bank (2014b, 2014c). 9 16 Integrating Social Accountability Approaches into EI Projects Sustaining and Scaling up Social Accountability Activities Sustaining and scaling up of SA efforts are complex and difficult. These activities generally should be designed to institutionalize relationships between government, industry, and citizens over the long term, rather than just the project. Too many initiatives are one-off exercises, especially at the project level, and have little lasting impact. Even while designing the SA initiative, it is important to develop a strategy for institutionalizing it over the longer term. SA requires time to implement and be accepted. Institutionalization requires long- term funding and commitment to SA and the availability of quality facilitators. Therefore it is important to focus on technical assistance and to provide training during early SA activities to develop the cadre of practitioners and facilitators that can carry the work forward. This means investing more up front, especially because SA tends to have a long gestation period. The objective is to achieve a critical mass so that SA moves from pilots toward mainstreaming. Task teams should consider the challenges to sustaining SA and scaling it up. Offi- cials may fear that grievances or negative feedback will be poorly perceived by their management. Task teams may try to address this concern through engaging regu- larly with high-level officials throughout the project cycle, promoting policy dialogue activities around issues of transparency, accountability, and participation. Consider incentives and rewards (e.g., performance-based disbursement, best practice awards) for implementing or responding to SA activities. This can be done in the context of learning events to share experiences and to motivate stakeholders. Sharing findings with a broader audience—for example, through a dissemination workshop and a website to make reports accessible online—can increase SA impact and build support for sustaining it. Consider the following measures that can facilitate institutionaliza- tion and sustainability: • Support networking, experience sharing, and support among SA practitioners. • Promote close links between government officials, media, CSOs, and communities. • Support ways of increasing the comfort level and recognition of monitoring done by NSAs in ministries and the project management units. • Share results with the public in a way that is meaningful to their everyday reali- ties and that engages them in their own spaces. • Develop tailored capacity-building activities, manuals, and other materials that government officials, CSOs, and communities can use beyond the project life cycle. If the SA activities are successful enough and there are sufficient reasons for expand- ing it, then the team may consider the following questions: Is the existing initiative appropriate for scaling up? Are any changes necessary for scaling up? That is why documentation of SA activities is useful, to understand what is working and why, so I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 17 any shortcomings can be corrected before scaling up. What works in one location might not work in other locations with different stakeholders. The original initiative may need adaptation and other adjustments. What additional burdens will scaling up place on SA actors? They may need capacity building. New actors may also be needed. Incorporating Gender into Social Accountability Activities Gender considerations are an important dimension of incorporating SA into EI proj- ects. Where EI projects work on the assumption that men and women are similarly impacted by EI, the implications of EI can isolate and overburden women, with repercussions for families and communities. Benefits and risks are often evaluated and measured at the community level, with little examination of the different impacts on men and women. EI can change the gender dynamics of a community—where men have increasing access to formal employment and decision-making spheres, women can be marginalized, with little say in how EI resources should be used. In fact, evi- dence suggests that a gender bias exists in the distribution of risks and benefits in EI projects: benefits accrue to men, whereas the costs, such as family and social disrup- tion and environmental degradation, fall most heavily on women. SA approaches and activities should take into account the constraints faced by women, such as: • Lack of women’s awareness about legal rights • Family-care responsibilities, and time and mobility constraints, that prevent women from meaningful engagement in politics and community affairs • Gender norms that pose obstacles to women’s political participation and col- lective action • Underrepresentation of women in decision making • Power imbalances that affect who participates and whose voice is heard Both the gendered impacts of EI projects and appropriate measures for gender responsiveness need to be factored into SA activities and strategies. Table 4 suggests a number of measures to improve gender responsiveness of SA in EI projects. 18 Integrating Social Accountability Approaches into EI Projects Table 4: Measures to Build Gender-Responsiveness into SA Strategies and Activities Project Activity Measures Planning and • Identify gender issues that will be most crucial for the sustainability and Analysis effectiveness of the EI project. Gender should be an important element of any upstream macro-social analysis. • Integrate gender-specific needs, demands, and considerations into project preparation through gender-disaggregated surveys, consultations, focus groups, and social assessments. Risk Management • Spell out risks for women and a risk-management strategy. Budgets • Develop gender-responsive budgets that aim to reflect women’s demands throughout the budget process policy-making stages, with a view to support increased allocation for gender equality. • Support inclusive financial literacy. Information • Use gender-sensitive appropriate approaches for information Dissemination dissemination, outreach, and consultation. • Use social media for communications and transparency with local communities. Consultation • Ensure that men and women are included in all stakeholder consultations. • Offer men and women separate consultations. • Identify appropriate roles of women and men and constraints to participation in consultations. Decision Making • Mandate a quota (or percentage) of women among nominated representatives from the community. • Create conditions that enable women to participate in decision-making committees such as scheduling meetings at times that are convenient for women. • Include women in decision making regarding community projects or programs. Hiring • Adopt legislation that requires companies to commit to gender-smart local recruitment. • Employ female fieldworkers and give them sufficient discretion to address the needs of female clients. • Ensure gender-fair hiring and workplace policies. • Implement local content policies that are gender-smart. Monitoring and • Ensure that all gender-specific activities are closely monitored. Evaluation • Ensure that gender-disaggregated data are collected. • Use gender-sensitive and gender-disaggregated monitoring indicators and outcomes. • Use gender-responsive monitoring and evaluation mechanisms to ensure that outputs benefit women. • Analyze data to demonstrate gender-specific impacts and aspects of EI. • Engage women directly in oversight functions. Grievance Redress • Establish gender-sensitive project grievance mechanisms (i.e., require culturally sensitive gender-awareness training for grievance mechanism staff ). • Require the presence of women in project grievance mechanism staff. • Provide multiple avenues for grievances, especially confidential and secure channels. • Provide an independent mediator and clear grievance processes. Sources: Eftimie, Heller, and Strongman (2009b); and Scott, Dakin, Heller, and Eftimie (2013). I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 19 The Extractive Industries Transparency Initiative Before proceeding to the main section of this note on the EI value chain, it is worth discussing the Extractive Industries Transparency Initiative (EITI) because it is often used as a platform for incorporating SA into EI operations. The EITI was launched in 2002 as a global initiative in which signatory companies and compliant countries publish accounts of funds paid and received in extractive industries, with civil society playing the role of third-party monitor. In mid-2015, there were 48 countries imple- menting the EITI, of which 31 were EITI-compliant and the other 17 countries were candidates for EITI compliance. The seven requirements for achieving the EITI Standard are: 1. Effective oversight by the multiple-stakeholder group 2. Production of comprehensive EITI Reports that include full government dis- closure of EI revenues and disclosure of all material payments to government by oil, gas, and mining companies 3. EITI Reports that are comprehensible, actively promoted, publicly accessible, and contribute to public debate 4. EITI Reports that include contextual information about the EI sector 5. Timely publication of EITI Reports 6. A credible assurance process applying international standards 7. Multiple-stakeholder group that takes steps to act on lessons learned and review the outcomes and impact of EITI implementation The EITI is a global standard that promotes revenue transparency and has a robust yet flexible methodology for monitoring and reconciling company payments and government revenues at the country level. The “reconciliation” process consists of an independent auditor collecting government data on payments from EI companies and company data on payments to government. These data should match. Where they do not, the discrepancy has to be explained. Where there is no convincing expla- nation, civil society should demand answers as to what happened to the relevant funds. 20 Integrating Social Accountability Approaches into EI Projects In its early days, the EITI focused on transparency in payments of taxes and royalties. This is a necessary, but not sufficient, step toward promoting SA. For example, at the national level, EITI supported publication of payment information but did not monitor how funds were used. In recent years, however, EITI’s focus has broadened to include other links of the EI value chain, including information on how EI rev- enues are used. The EITI is supported by a multi-donor trust fund (MDTF) managed by the World Bank. It funds technical assistance for countries that wish to become EITI candidates and, ultimately, EITI compliant. The World Bank provides technical assistance for establishing the required institutional structures, gathering and reconciling data, and publishing EITI reports. The World Bank implements several programs dedicated to supporting civil society engagement in the EITI. These programs strengthen civil society’s ability to hold governments and companies accountable to commitments made under the EITI, and they aim to increase civil society’s voice, creating a more receptive environment for civil society participation and improving civil society’s ability to communicate information disseminated through the EITI. In recent years, the World Bank’s extractives team has contracted the National Resource Governance Institute (NRGI, formerly Revenue Watch International, RWI), in 2010–2011, in 2013–2014, and with a third contract under implementa- tion. The NRGI program was funded by the EITI MDTF. The 2013–2014 NRGI program focused on two main objectives: (i) supporting civil society in pursuing EITI implementation, organizing a broad constituency, participating effectively in the earliest stages of the process, and initiating EITI processes that are progressive and likely to deliver accountability gains from the start; and (ii) empowering civil society to demand an EITI process that is relevant to broader local priorities on EI sector governance, public accountability, and development. NRGI worked to strengthen CSO engagement in EITI-implementing countries where the NRGI has local partners. The NRGI developed learning tools and helped its local partners to conduct in-depth training for civil society with guidance for effective participation by domestic civil society groups. The World Bank also pro- vided a grant to the Publish What You Pay (PWYP) International Secretariat to support advocacy efforts by its country-based local coalitions. The World Bank has also provided direct support to civil society in EITI-candidate and EITI-compliant countries, to support CSOs to define activities to be funded by the MDTF grants based on national priorities for effective EITI participation. These activities include information dissemination, capacity building, mobilization, advocacy, networking, and coordination (see Box 5 for examples from Mongolia and the Kyrgyz Republic). The 2013–2014 program improved the effectiveness of EITI reporting and processes, stimulated important policy debates, and advanced cross-stakeholder solutions to governance challenges. The NRGI developed a guide to the EITI standard. In the Philippines, a CSO coalition (Bantay Kita) organized the first civil society national conference on EITI. In Burkina Faso, RAJIT (le Réseau Africain de Journalistes pour I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 21 Box 5: Creating Capacity and Demand for Transparency and Accountability through Civil Society Capacity Building The EITI MDTF recognized that without robust engagement of civil soci- ety in the EITI, the process could become externally driven and unsustain- able. To increase local understanding of and demand for transparency, the EITI MDTF funded a series of programs to support civil society capacity for increased engagement in the EITI. The most recent program provides support for intra-civil society consultation on key issues limiting civil soci- ety engagement in the EITI, such as lack of capacity or understanding, weak civil society networks, and so forth. This program has been launched in 19 countries and provides over US $1 million directly to civil society groups in support of their demands for transparency and accountability. In Mongolia, the EITI CSO Direct Support Program funded activities to increase CSO engagement in the EITI. The Publish What You Pay (PWYP) Coalition was hired to conduct data analysis to create a multiyear data- base of payments disaggregated by soum (district) and mine operator. This data analysis provides new ways to present data to civil society, to increase awareness around the EITI, and to highlight key issues in data-collection methodology. The PWYP coalition is now able to present these findings to the EITI secretariat. Civil society members have used this opportunity to increase the availability of EITI data, as well as to strengthen their own advocacy skills. Based on data made available through the PWYP analysis, capacity building was conducted at both the local and national levels, intro- ducing civil society to the EITI process and data, to empower them to be more engaged in the EITI process nationally as well as in debates on revenue transparency. In October 2012, an intensive two-week boot camp was held for TV journalists to improve their investigative reporting skills on mining. Training enhanced local and national TV reporters’ knowledge of conflict issues surrounding the mining industry and ability to produce in-depth reports. Finally, a comprehensive local CSO training program was devel- oped and implemented by the NRGI on EITI in mining communities. The Kyrgyz Republic has substantial mineral deposits, but their develop- ment suffers from poor governance, lack of transparency, and low investor confidence. The Kyrgyz Republic was declared an EITI-compliant country in March 2011, and CSOs have been actively involved in EITI since 2004. A 2012 capacity-building workshop was designed to enable local CSOs to understand the EITI process and its relevance to national and local pub- lic budgeting and expenditure processes. The workshop was also designed to build knowledge and managerial capacity to initiate, implement, and sustain EITI activities, including small projects. A small grants program provided support to CSOs representing mining-affected communities in all seven provinces of the Kyrgyz Republic, aimed at strengthening CSO 22 Integrating Social Accountability Approaches into EI Projects contributions to the EITI implementation process at the subnational level. The selection panel identified and supported seven small projects that ranged from $3,900 to $6,500. These projects trained local residents, local authorities, and civil society representatives about EITI and engagement in its initiatives, as well as in community decision-making processes. The projects set up multiple-stakeholder groups consisting of stakeholders such as local community leaders, women and youth, local authorities, CSOs, and mining companies. This improved inclusiveness of local interests and priorities in decision making, engagement, and planning and implementa- tion processes, building better conditions for the improved interaction, trust, and cooperation in the community. l’Intégrité et la Transparence) completed the first research on the impact of tax incen- tives on EITI-reported revenues undertaken by local stakeholders. In Zambia, the Center for Trade, Policy and Development (CTPD) and ActionAid facilitated the first formal civil society engagement with the National Assembly on the EITI. Over 1,200 people have participated in activities under this program. These various activi- ties have contributed to improved EITI data quality and better use of the EITI data. Box 4 provides two country examples of the EITI. Box 6 provides a list of some of the types of SA activities that the EITI has been undertaking to increase its effectiveness. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 23 Box 6: Examples of Social Accountability Activities Undertaken as Part of the EITI Information and communication activities • Encourage transparency on payments of taxes and royalties. • Urge government to report on revenue utilization. • Make EI data available through an open data initiative. • Publish rules that determine allocation of EI revenues. • Identify policy recommendations for improving subnational revenue management. • Support engagement with civil society and other stakeholders for the dissemination of the EITI audit report. • When distributing “easy-to-understand” versions of the EITI audit report, organize informational meetings at the community level so such reports can be clearly explained to citizens. • Conduct local CSO training program on EITI in mining communities. Capacity building of the EITI Secretariat, multiple-stakeholder groups, and civil society • Build CSO capacity to understand and utilize information from the EITI. • Increase CSO capacity to engage in the EITI. • Strengthen CSO advocacy skills. • Improve media skills for investigative reporting on EI issues. • Create local civil society networks to empower local EITI monitoring. • Incorporate SA principles into the training course of EITI staff, CSOs, local government officials, and EITI multiple-stakeholder groups. 24 Integrating Social Accountability Approaches into EI Projects Integrating Social Accountability Activities along the Extractive Industry Value Chain This section summarizes possible social accountability entry points and activities in EI operations using the EI value chain (Figure 1). Suggested SA approaches cor- respond to challenges World Bank task teams may encounter at various links in the value chain and steps in the project cycle. The section explores the issues, opportuni- ties, and challenges for integrating SA under each link. It also provides project and country examples using those SA approaches. The EI value chain is a model for visualizing the various components of the EI sec- tor. It is used here because it provides a useful framework for considering SA entry points and approaches and has wide familiarity within the World Bank and the EI sector more generally. Each of the five links along the value chain has significant implications for the development impact of the extractive industries—from how and to whom contracts are awarded, to how social environmental regulations are created and enforced, to who receives taxes and royalties, how these benefits are shared with citizens, and with what sort of accountability. SA interventions have the potential to improve how each link contributes to the development benefits of the sector. Although the EI value chain provides a fairly comprehensive view of the extractives sector, it does not cover the full extent of issues and activities related to the extrac- tive process. For example, it does not address overarching EI industry policy ques- tions or that an EI project will be approved. Nonetheless, many of the entry points and suggested SA activities described for the five links of the EI value chain are also Figure 1: Extractive Industry Value Chain TRANSPARENCY, ACCOUNTABILITY, AND PARTICIPATION REGULATION REVENUE IMPLEMENTATION AWARD OF AND COLLECTION MANAGEMENT OF SUSTAINABLE CONTRACT MONITORING OF OF TAXES AND AND DEVELOPMENT AND LICENSES OPERATIONS ROYALTIES ALLOCATION POLICIES AND PROJECTS I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 25 relevant at this stage. For example, impacted communities and civil society should be educated about policy issues and proposed projects, consulted, and provided chan- nels for feedback and grievances. Civil society capacity to engage in discussions on EI policy and proposed projects can be strengthened. There should be oversight of policy formulation and EI project approval, such as by parliamentary committees, to help ensure that EI policies and proposed projects serve the public interest and are accountable to the general public. Generally, the TAP principles (transparency, accountability, and participation) should be applied using the same kinds of SA approaches and tools described in the rest of this section. AWARD OF CONTRACT Link 1: Award of Contracts and Licenses AND LICENSES The first link in the value chain concerns the award of contracts and licenses. Under this link “Governments grant hydrocarbon or mineral explorations, development, and production rights in particular areas or blocks by means of concessions, leases, licenses, or contracts depending on their legal systems.”10 Activities at this stage are critical to laying the foundation for SA in the EI operations because this stage out- lines the mutual obligations between each company and the government. Transparency around how agreements are reached, as well as of the conditions and value of extractive industries contracts and licenses, is critical to preventing or reduc- ing conflict. For example, multiple claims on a mineral deposit are quite common. It is essential to ensure that the terms and obligations of any contract award are widely known and that community members, civil society, and their representatives are aware of what revenues, benefits, and impacts should be expected, especially at the local level. Although common arguments against contract and license disclosure often include concerns about a country’s competitiveness in attracting more investment, expert sources such as the Guide on Resource Revenue Transparency (2007) of the Interna- tional Monetary Fund (IMF) point out that contract terms are often widely known within the industry, creating little strategic advantage in not publicizing contracts. In countries where contract disclosure does takes place (e.g., Peru), there is little evidence that contract transparency has affected the level of investment in countries where contracts have been disclosed. Given that the IMF has endorsed contract trans- parency since 2007, that in 2012 the IFC made contract transparency a requirement for extractives projects it finances, and that the EITI encourages contract transpar- ency through the EITI Standard, contract transparency should be simply treated as a normal aspect of doing business. 10  Mayorga Alba (2009, p. 4). 26 Integrating Social Accountability Approaches into EI Projects Key issues Poor civil society understanding of licensing, contracting, procurement, how com- panies are paid, and company and government obligations related to licenses and contracts can create perceptions of injustice among stakeholders. This can lead to tensions between companies, communities, and governments. Increased transpar- ency, combined with civil society participation in contract monitoring, can reduce misperceptions and potentially build trust. Contract transparency can be a contentious issue among governments and private- sector companies. For reasons of corporate security and competition, many com- panies are reluctant to make contract information public. To date, many countries have only limited transparency in EI licensing, procurement, and contracting. This reflects few precedents and/or incentives for transparency from the industry “sup- ply” side. It may also reflect limited opportunity and capacity from the civil society “demand” side. However, contract and licensing transparency is essential for giving citizens information on local operators and their ability to hold companies account- able for meeting the terms of contracts. Enhanced civil society capacity and opportu- nity to monitor licensing, contracting, and procurement may promote transparency and help to curb corruption and fraud in EI contracts and operations. Box 7 explains the meaning of disclosure of contracts and licenses. Box 7: What Does “Disclosure” of Contracts and Licenses Mean? The World Bank Group is emphasizing the importance of disclosing con- tract and licensing information, especially in the extractive industries. For example, since January 1, 2012, the IFC has made disclosure of contract information mandatory for IFC-financed private extractive companies. This increases opportunities for awareness, analysis, and monitoring of contracts between the government and the private sector. Considering the complex technical language of many legal documents, posting of legal texts or documents, whether online or on community message boards, is not sufficient. Impacted communities may not fully comprehend legal ter- minology. Therefore, information must be disclosed in a format that the general public can understand. Methods to increase transparency include simplification of legal texts, translation of simplified texts into local lan- guages, and presentation through accessible means (e.g., through radio programs or pictures). Each country needs to determine, based on inter- national agreements and best practices, how to address issues such as the length of time between contracting and licensing, public disclosure, the length of the reporting period, and the types of disclosure platforms that will enable governments to most effectively engage with civil society and affected communities. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 27 Box 8: Entry Points for Accountability in Awarding Contracts and Licenses (Link 1) • Support institutionalization of transparency in contracting and licensing— including mechanisms for sharing contracting and licensing processes and decisions—such as through transparent bidding systems, e-procurement, and publishing contracts and licenses on websites and through other easily accessible channels. • Make transparency of contracts and licenses a requirement for EI opera- tors. Reduce any legal basis for exceptions for contract disclosure, and develop mechanisms to make contracts accessible and disseminated locally. • Create transparent and accessible cadastral systems. • Work on transparency in government contracting through right-to- information (RTI) laws and open government policies. • Develop mobile phone apps, online geographic information system (GIS) mapping, and other IT tools that give citizens information on contracts. • Promote civil society input in the design of the legal framework to ensure that civil society has the knowledge, access, and ability to make use of any feedback and grievance redress mechanisms. • Support monitoring by civil society of how contracts and licenses are awarded and the terms implemented. • Build civil society capacity to demand, understand, and use contract information. Opportunities for accountability Social accountability activities can strengthen legal frameworks for licenses and con- tracts, enhance government capacity to enforce them, make information more acces- sible on how licenses and contracts are awarded, give citizens a chance to monitor how contracts and licenses are awarded, and hold companies accountable for living up to the terms of contracts. Box 8 lists some common entry points for promoting accountability in the award of contracts and licenses (Link 1). World Bank support for transparency in contracts and licenses To increase availability and access to information, some projects have established resource and information centers to provide communities with information on extrac- tive industries. In Ghana, seven petroleum contracts were released to the public in 2011 (see Box 9). Having information accessible for the monitoring of these contracts allows for greater transparency and accountability. Civil society coalitions are respond- ing by developing innovative monitoring techniques such as mobile phone apps. In Liberia, civil society is increasing its monitoring of the growing oil sector and is devel- oping government recommendations for contract transparency and participation. 28 Integrating Social Accountability Approaches into EI Projects Box 9: Progress in Making Ghana’s EI Contracts Public Ghana’s first EITI report recommended that all of Ghana’s mining con- tracts, including investment agreements, be made public. Ghanaian CSOs made concerted advocacy efforts to make EI contracts public. In May 2011, several oil company contracts were published on the U.S. Securities and Exchange Commission website as part of the company listing pro- cess. Soon after, the Ghanaian Minister of Energy ordered the publication of those oil contracts, which were then posted on the ministry website. Nevertheless, constraints to transparency remain. There is no clear legal requirement for petroleum or mining contracts to be published, and the Ghana National Petroleum Corporation does not provide any information on contracts it enters into on behalf of the state. The World Bank Institute and the World Bank Africa Region launched a program in West and Central Africa (Ghana, Liberia, Nigeria, and Sierra Leone) on contract monitoring in 2010 that ended in 2014. A separate extractives-focused program was launched in 2012 in partnership with RWI (now NRGI) that specifically targeted Francophone African countries (pilots in Burkina Faso, Cameroon, DRC, Guinea, Niger; training in Central African Republic, Chad, Côte d’Ivoire, Mali, Mauri- tania, Republic of Congo, Togo). The program provided training and supported the creation of action plans to help stakeholders improve monitoring of extractives contracts. The Extractives Governance Global Solutions Group/Governance for Extractive Industries team (part of the Governance Global Practice) is currently working with civil society, government, and industry on mapping extractives operations and a range of related contracting, licensing, and socioeconomic data. This enhanced trans- parency mechanism, which may also be used to enable citizens to begin providing data themselves, democratizes information on extractives operations by making it accessible. This empowers dialogue at a local level. This contract monitoring road- map provides step-by-step guidance, case studies, and resources. Box 10 reports on contract monitoring in East Asia. Table 5 lists suggested SA activities to improve transparency, accountability, and citizen participation in the awarding and monitoring of EI contracts and licenses. These activities address five main challenges: (i) weak legal frameworks; (ii) weak government enforcement of legal frameworks; (iii) government lack of interest in transparency; (iv) lack of transparency in contracts, licenses, and laws; and (v) limited civil society and government capacity in contracts and licenses. All these can make it hard for civil society to ensure that mining licenses are issued responsibly, that mineral rights are respected, and that companies agree to con- tracts that respect impacted communities and the environment. Table 5 illustrates how SA approaches can address these challenges. It also contains examples of these approaches. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 29 Box 10: Contract Monitoring Using Community Scorecards in East Asia In a partnership between the Affiliated Network on Social Accountability— East Asia and Pacific Region (ANSA-EAP), the World Bank Institute, and the Revenue Watch Institute, CSOs were trained to use community score- cards as a tool for SA in the extractive industries. Training activities brought together community and corporate representatives to review, monitor, and discuss company commitments to social investments such as water, health, and local libraries around mines (Timor Leste); company implementation of commitments to communities on health and safety (Indonesia); and roy- alties, taxes, environmental rehabilitation programs, and information dis- semination and transparency (Philippines). Each civil society group helped facilitate an iterative discussion process that helped bring communities and companies into dialogue and collaborative problem solving. Where central governments lack the resources to do comprehensive top-down monitor- ing, participatory local-level monitoring can provide a powerful monitoring and evaluation tool. For more information on the ANSA/RWI community scorecard activities, see the ANSA-EAP website: www.ansa-eap.net. Table 5: Possible Social Accountability Activities for Contracts and Licenses Possible Activities Challenges (Approaches/Tools) Examples Government • Adopt internationally recognized Ghana: The World Bank made not interested in transparency standards (e.g., IFC’s disclosure of information, based transparency contract disclosure requirement, on transparency principles, one the Natural Resource Charter, or of its lending conditions. For this IMF’s Guide on Resource Revenue reason, the government of Ghana Transparency). committed itself to transparency • Introduce ATI or RTI laws. in EI contracts. Work with relevant parliamentary committees to raise awareness about transparency. Promote legal mandates for transparency in contracts and licenses. • Introduce open-data activities (e.g., joining the Open Government Partnership [OGP]11). • Make transparency and disclosure of information part of World Bank lending conditions. 11 continues 11  oining the OGP is not just for governments; CSOs are also welcome to join even if their country is not a member. By joining the OGP, J CSOs can learn from other CSOs, identify priority areas for engaging their government, and move toward constructive engagement with their governments. Through the OGP, some countries, such as the United States, are pushing for EITI implementation through open- government data. 30 Integrating Social Accountability Approaches into EI Projects Table 5: Continued Possible Activities Challenges (Approaches/Tools) Examples Lack of transparency • Promote publication of bidding Colombia, Liberia, Peru, in contracts and criteria, bid evaluation processes, Timor-Leste, and the United licenses factors in winning a license, and States: The full text of minerals how they are weighted so the contracts and leases on public public can obtain information on land are made public. any concession. Publish all bids. • Introduce e-bidding and disclose Egypt: All contracts are made information on contracts and public (while licenses may be licenses through the e-bidding awarded through negotiated deals platform. or bidding). • Disclose lease, concession, license, Afghanistan: A new minerals and contract information to the policy calls for public tenders and public. publication of bids and contracts. • Work with open-government initiatives on legal, regulatory, and Nigeria: The constitution technical transparency initiatives mandates publication of all oil to create opportunities for making and mineral contracts in the contracts and licenses available. country’s official gazette. • Clearly state which government Botswana: The mining licensing agencies have the responsibility system is fully automated and to disclose information on legal transparent. frameworks used for contracts and licenses. Ghana: Transparency and • Ensure the cadaster system disclosure of bills (e.g., the is transparent and accessible Petroleum Revenue Management (including online) for miners and Act) is a lending condition of the the public. World Bank. Weak legal • Promote government consultation Ghana: Broad consultation framework with civil society when drafting was a lending condition for the legal frameworks. Petroleum Revenue Management • Promote the inclusion of Act. responsibilities for the social and environmental dimensions Guinea: The 2011 Mining Code of EI laws and regulations (e.g., was developed through extensive submission of plans, monitoring, consultation with public, local, and reporting). and international civil society • Assist governments in members, international donors, standardizing procedures and and the private sector. criteria subject to law and South Africa: The Mineral regulations, including disclosure of and Petroleum Resources and information, grievance redress, and Development Act requires mining social and environmental plans. companies to submit a Social and This minimizes room for “subject Labor Plan as part of any mining to negotiation” contracts. application. continues I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 31 Table 5: Continued Possible Activities Challenges (Approaches/Tools) Examples Weak government • Establish an independent Afghanistan: An international enforcement of legal oversight institution to monitor advisory panel (IAP) was frameworks government’s legal enforcement established at the Aynak mine activities. This can be an existing and was staffed by international government institution (e.g., an industry experts who were ombudsman office, anticorruption contracted by the government agency, or parliament) and/or a to provide third-party oversight multiple-stakeholder oversight on the tender process. The framework. (Approaches: third-party IAP aimed at enhancing monitoring) sector governance by ensuring • Support pilots to establish transparency, competition, independent third-party and fairness in procedures and monitoring. (Tools: community processing of contracts with monitoring, community scorecards, mining companies. third-party monitoring) • Support creation of complaint- Indonesia: ANSA-EAP supported handling mechanisms. (Tools: pilots of community scorecards grievance redress mechanism, public that facilitated community hearings) monitoring of contracts. Limited civil • Support civil society capacity Ghana: The World Bank, society capacity building and information other donors, and a civil society on monitoring campaigns to inform people of network organized country-wide contracts and their rights. (Tools: information roadshows on the petroleum licenses campaign, such as roadshows/forums) revenue management bill and • Provide training for journalists and supported creation of a network media practitioners on data and of oil- and gas-focused CSOs. information analysis. The World Bank Country • Provide training for civil society, Management Unit (CMU) members of parliament, and published the Petroleum Revenue other institutions to monitor EI Management Bill on the World contracts and licenses. Bank website to encourage public • Support joining WBI’s Contract debate. Oxfam organized an SMS Watch activities and conferences. campaign to build awareness • Participate in the WBI’s Contract about the petroleum bill. The Monitoring program. bill was revised with stronger • Support joining the OGP as a provisions for transparency and CSO member. accountability after thousands of people protested the former, weaker bill. Kenya and Moldova: The World Bank Institute (WBI)—in cooperation with other donors, agencies, and institutions— provided training to journalists on how to identify stories and conduct analysis on information received. 32 Integrating Social Accountability Approaches into EI Projects REGULATION AND Link 2: Regulation and Monitoring MONITORING OF OPERATIONS of Operations Link 2 in the EI value chain refers to the regulation of the sector as well as monitoring of operations to ensure that they meet regulatory standards. For a regulatory frame- work to have a strong impact, it needs to be complemented by a strong monitoring and enforcement mechanism. According to the World Bank, “Environmental [and social] regulations should be in place, as should a competent authority with the capac- ity to approve and monitor environmental impact assessments and management plans and enforce compliance. Environmental and social impact mitigation and monitor- ing [should] involve early consultation and participatory monitoring practices at the community level. Regular audits should be carried out to assess production and export volumes, valuation of minerals and hydrocarbons, and the cost of operations.” Opportunities for social accountability Creating opportunities for civil society to monitor the implementation of contracts and operations can be beneficial in a number of ways. It can help decentralize moni- toring so that accountability, monitoring, and enforcement are not solely dependent on government or private-sector personnel; it can increase transparency and reduce corruption at the local level; and it can improve relationships between communities, government, and companies. SA mechanisms can provide bottom-up engagement of civil society and impacted communities to help monitor operations and advocate for adherence to regulations. This can reduce burdens on government monitors and reduce citizen and community perceptions of having no voice in how extractive industries operate. Dissemination of clear, straightforward information to the general public, and particularly to civil society and impacted communities, is necessary for participatory contract monitor- ing. Incorporating SA into regulations and monitoring creates feedback mechanisms through which people can get information about company and government obliga- tions, have access to operational information to monitor the extent to which com- panies and governments are adhering to obligations, and then have forums in which to raise concerns and shed light on monitoring results. Box 11 lists some common entry points for introducing SA approaches in the regulation and monitoring of EI operations. Box 12 describes an example of participatory environmental monitoring in Peru. Box 13 describes the use of an independent group for monitoring both envi- ronmental and poverty reduction impacts of the Chad–Cameroon Pipeline Project. Box 11: Entry Points for Social Accountability in the Regulation and Monitoring of Operations (Link 2) Regulations on Operations • Promote consultation and feedback in the design of regulations and in monitoring of regulatory compliance. continues I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 33 Box 11: Continued • Promote regulations that specify legal sanctions if regulations are violated. • Disclose laws and regulations in ways that are easily understood by and accessible to the general public. • Support regulations that require civil society capacity building for com- munity monitoring. • Create opportunities for public discussion on operator compliance with environmental and social regulations. • Provide information on the government entities that are responsible for regulations. Monitoring of Operations • Introduce participatory monitoring to allow citizens and civil society to be part of monitoring and to complement government monitoring of operations, increasing government’s ability to hold companies account- able for their impacts. • Train CSOs to monitor company compliance with regulations. • Create independent community-based monitoring structures. • Establish grievance redress mechanisms and provide technical assistance for these mechanisms. • Publicize the findings of monitoring activities. • Build the capacity of relevant ministries, agencies, and local govern- ments on SA mechanisms so they are able to be responsive to citizens and can better hold mining companies accountable for their commit- ments and impacts. • Support initiatives that help citizens and civil society understand their rights and the relevant legal and regulatory protections for the sector, to hold governments accountable for enforcement of the law. Table 6 suggests SA activities to improve transparency, accountability, and citizen participation in the regulation and monitoring of EI operations. These activities relate to four main challenges: (i) weak regulations, leading to limited potential for accountability; (ii) limited transparency and awareness of regulations; (iii) weak capacity of government agencies to monitor regulatory compliance; and (iv) weak civil society capacity to monitor regulatory compliance. Table 6 illustrates how SA approaches can address these challenges and provides examples of these approaches. 34 Integrating Social Accountability Approaches into EI Projects Box 12: Community Environmental Monitoring in the Peru Liquefied Natural Gas Project The Peru Liquefied Natural Gas (PLNG) project ($4 billion) was launched in January 2007. The project involves the construction of a new 34-inch- diameter pipeline to transport natural gas along 408 kilometers from the Andes to the Pacific coast. The local community monitoring program was launched in 2008 and was implemented in 35 communities along the pipe- line. The construction company selected a respected, independent local NGO, ProNaturaleza, to (i) act as an independent monitor; (ii) to design and implement the management and communication structures necessary for the monitoring mechanism; (iii) to develop a capacity-building program and relevant training materials, field manuals, and monitoring plans for local communities; and (iv) to develop an information database. To process moni- toring results, a user-friendly database was developed to track actions. The design phase comprised several stages: program validation, selection of monitors, and training of monitors. Regular meetings were held to ensure a clear understanding of the monitoring program and to respond to pro- gram expectations. The community selected a total of 84 monitors (includ- ing local authorities, governmental offices, and civil society) in a voluntary and participatory process. For the training of monitors, 57 workshops in 48 locations were organized, with approximately 2,000 people in atten- dance. Community monitors were in the field for 10 days every month with a Program Operator specialist. The participatory model has strength- ened the community and monitors’ capacity to understand the monitoring processes and to improve community-based environmental management practices. The community monitoring process has helped promote proj- ect transparency and accountability. A website was created to disclose the monitoring results to the general public and to validate it with communi- ties. Because monitors have provided the project implementers with timely information regarding community concerns, they have gained the trust and respect of the larger community and also helped prevent potential conflict. Source: World Bank Social Accountability E-Guide. Peru: Community monitoring of Peru’s Natural Gas Pipeline Project. Box 13: Independent Monitoring in the Chad–Cameroon Petroleum Pipeline Project At the insistence of the NGOs that had closely followed the progress of the Petroleum Development and Pipeline Project, an international advisory group (IAG), consisting of six civil society representatives, was proposed, funded, and created by the World Bank Group (WBG). The qualifications of the IAG’s members were specified in its TOR, which were developed continues I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 35 Box 13: Continued in consultation with NGOs. The IAG visited Chad and Cameroon at least twice a year and reported periodically to the president and Board of Execu- tive Directors of the WBG. All IAG reports were made public the same day they were submitted to the WBG. To aid in the accuracy of their reports and also to demonstrate their openness, the IAG had adopted the prac- tice of holding debriefing meetings with the major stakeholders, including NGOs, at the end of each mission. The IAG fostered continuous dialogue between the project sponsors, the governments, and the NGOs, ensuring that project information was regularly disseminated to civil society in a transparent way. The IAG’s systematic inclusion of civil society in its moni- toring of the project served to verify and dignify the expressed concerns of civil society and actively supported the participation of civil society. Source: World Bank Social Accountability E-Guide. Chad & Cameroon: Petroleum Development & Pipeline Construction: Independent monitoring through the Independent Advisory Group (IAG). Table 6: Possible Social Accountability Activities for Regulation and Monitoring of Operations Possible Activities Challenges (Approaches/Tools) Examples Weak regulations, • Institutionalize consultation of Industry Wide Audits leading to limited civil society in the creation and potential for amendment of legal frameworks. South Africa (2010) and the accountability • Encourage EI companies to adopt Philippines (2011): Both audits are internationally accepted standards government-led initiatives. In South on sector governance (e.g., the IFC’s Africa, companies that do not comply Stakeholder Engagement: A Good with their obligations are given 120 Practice Handbook for Companies days to comply. In the Philippines, as Doing Business in Emerging Markets, a result of the audit and the policy of the Natural Resource Charter’s Natural “use it or lose it,” about 900 mining Resource Charter, and the IMF’s Guide applications were rejected and 250 to Resource Revenue Transparency). were approved. • Encourage mining companies to adopt Social Accountability 8000 (SA8000), the international standard for amelioration of working conditions. Limited • Disclose information on who is Zambia: The Environmental Council of transparency responsible for what so citizens can Zambia (ECZ) posts new environmental and awareness of hold central and local government impact assessments (EIAs) on its website regulations authorities accountable. for public comments. By law, the ECZ • Disclose monitoring results is required to provide copies of EIAs to on inspection and regulatory local government units, parliamentarians, enforcement, and the results of the NGOs, CBOS, and interested and PSIA, SESA, and other assessments, affected parties so they can post copies in a way the general public can easily in public areas, near proposed mining access and understand. sites, and in newspapers. However, in • Introduce open-data activities (e.g., join practice, copies are rarely distributed by the OGP for governments and CSOs). the ECZ, and they do not receive public • Provide a forum for validating and comments. providing feedback on monitoring results, and promote discussion at the local level. continues 36 Integrating Social Accountability Approaches into EI Projects Table 6: Continued Possible Activities Challenges (Approaches/Tools) Examples • Enhance transparency by building Peru: Informing citizens about capacity of journalists, bloggers, and ATI through various media sources others to make information public empowered them to demand (e.g., through newspapers, television, transparency on EI revenues and to community radio, etc.). (Tool: hold local authorities accountable information campaign) to local development commitments through dialogue with the mayor. Turkey: In the Baku-Tbilisi-Ceyhan (BTC) pipeline project, the company published simplified presentations on the ESIA and made them available at the community level. Afghanistan: The World Bank is working with the Ministry of Mines and the EITI to explore opportunities for making EI data available through an open-data initiative. Weak capacity • Support the development of capacity Monitoring by Parliament of government in key management and regulatory agencies to institutions, such as the ministry South Africa: The Constitution gives monitor of mines and natural resources, the Parliament authority for overseeing regulatory for oversight and governance of the executive branch. Therefore, compliance extractive industries. parliamentarians can use this oversight • Establish an independent monitoring authority to monitor the executive institution to conduct monitoring branch’s management of mining on behalf of the government. The companies to ensure the enforcement of process of the establishment of this companies’ obligations. Furthermore, institution should be transparent. citizens can ask their parliamentary • Invite civil society and community representatives to use this oversight members to participate in, or mechanism to obtain information on monitor, the inspections along with mining companies and their activities. the inspection panel, especially Multiple-Stakeholder Monitoring where government is responsible for monitoring. The Philippines: Multiparty • Support community-based impact Monitoring Teams (MMTs) were assessment, human rights impact formed to monitor the Deep Water assessment, and gender impact Gas to Power Project. The MMTs assessment. are comprised of local government representatives, CSO representatives, community leaders, provincial and local environmental officers, and other stakeholders. MMTs monitor environmental and social impacts at the community level during the implementation of projects. Peru: Community Participatory Monitoring mechanisms have been developed for community members, regulatory agencies, and independent agencies to come together and monitor the environmental and social performance of extractive industry companies during the construction phase of mining projects. continues I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 37 Table 6: Continued Possible Activities Challenges (Approaches/Tools) Examples Weak civil • Build capacity of civil society to Ecuador: Local communities are society capacity monitor EI operations at national, involved in the monitoring of to monitor regional, and local levels. environmental and social impacts regulatory • Promote participatory monitoring of mining activities (particularly compliance of operations and compliance with on small-scale mining) through regulations. (Tools: community the creation of environmental monitoring, community scorecards, committees. grievance redress mechanism, public hearings) Peru: Participatory monitoring in the • Create opportunities for civil society form of a mesa de dialogo (platform to review and comment on social and for a dialogue) has been formed with environmental impact assessments, civil society, industry, and other etc. stakeholders (e.g., the Compliance • Provide parallel, complementary Advisor/Ombudsman of IFC). training to civil society and local Nigeria: In partnership with the government officials to support EITI Open Knowledge Foundation (an candidacy and transparency and international CSO located in the UK), accountability throughout the EI the Stakeholder Democracy Network value chain. (a CSO working to enhance social accountability in Nigeria) created interactive mapping that consolidates citizen feedback on oil spills and other reports on environmental and social impacts of the extractive industry. DRC: Mining companies initiate community engagement by disclosing information prior to the start of the project. Adastra Minerals, a mining company, utilized community radio and texting (SMS) to overcome language barriers to engage and consult with the community. REGULATION COLLECTION AND OF TAXES AND MONITORING ROYALTIES OF Link 3: Collection of Taxes and Royalties OPERATIONS Taxes and royalties—and subsequently revenue management and allocation—are some of the most important issues that concern communities. They can lead to mis- understandings, misinformation, and tensions around extractive industries opera- tions. How much companies pay, and how much governments receive, can affect how civil society views extractive industries operators—as partners in sustainable development, or profiting at the country’s expense. 38 Integrating Social Accountability Approaches into EI Projects Transparency and accountability in extractive industry taxes and royalties contribute to perceptions of stability and good governance in the sector, and therefore to invest- ments. They can increase awareness of companies’ contributions to development, national stability and a good business environment. For example, ratings agencies like Standards and Poor’s now include a “Political Score” measuring “transparency and accountability of institutions, data and processes . . . including [a country’s] perceived level of corruption.” SA can help with tracking funds, reducing waste and corruption, improving the use of extractive industry revenues for development, decreasing tensions between companies and civil society, and improving perceptions of benefits from extractive industries. Through initiatives like the EITI, revenue transparency has become a key element of a strong investment climate and donor support. Opportunities for accountability To take EITI beyond a transparency focus and create a sustainable accountabil- ity relationship between civil society and government, the focus has expanded to strengthening civil society’s capacity to understand and use EI data. In order for civil society to be able to identify discrepancies in payments and revenues, tax and royalty codes and information on collection need to be understandable and easily accessible. It must be clear who is responsible for paying what to whom and when. The proce- dures for intergovernmental transfers must also be clear and accessible. Independent auditing bodies may be created to monitor taxes and royalties. Audit results should be published. Box 14 lists some common entry points from introducing SA approaches in the collection of EI taxes and royalties. Table 7 proposes SA activities to improve transparency, accountability and citizen participation in the collection of taxes and royalties. These activities concern three main challenges: (i) weak legal framework for enforcing collection of taxes and roy- alties, (ii) limited disclosure of information by government agencies on the collec- tion of taxes and royalties, and (iii) limited capacity of civil society to demand for information and hold government accountable for the collection of taxes and royal- ties. Table 7 shows how SA approaches can address these challenges and provides examples of these approaches. Box 14: Entry Points for Social Accountability in the Collection of Taxes and Royalties (Link 3) • Incorporate transparency mechanisms into laws. • Disclose taxes and royalties collected by the government • Support CSO participation in the EITI and other transparency initiatives. • Build civil society capacity to understand and monitor revenue collection. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 39 Table 7: Possible Social Accountability Activities for the Collection of Taxes and Royalties Possible Activities Challenges (Approaches/Tools) Examples Weak • Conduct EI production audits that enforcement of are overseen by parliament and tax and royalty independent oversight bodies to collection ensure accuracy in the collection of revenues. Limited • Disseminate information on who Ghana: The 2011 Petroleum Revenue disclosure of must pay what. (Tool: Information Management Act mandates that the information campaign) government publish information on and data by • Support open data activities (e.g., receipts from petroleum companies, government encourage government and CSOs on a quarterly basis, online and in agencies on to join the Open Government national newspapers. the collection Partnership or utilize BOOST). of taxes and • Encourage mining companies to Uganda, DRC, and some Sub- royalties disclose information of taxes they Saharan African countries: Following pay and royalties they earn, and the example of Uganda, which governments to disclose the taxes adopted BOOST for disclosure of received and royalties paid. public financial information, the • Create forums for civil society to World Bank has begun to work with ask questions and to learn what the government of DRC and other mining revenues are received. Sub-Saharan African countries to introduce BOOST for disclosure of public financial information. Limited • Build CSO capacity to request, EITI Civil Society Direct Support capacity of analyze and understand EI tax and Program: The EITI MDTF helped civil society to royalty data. build civil society capacity to better demand for • Train CSOs on how to access understand and engage in the EITI information and use project payment data for process and to hold governments and hold companies covered by payment and companies accountable for government disclosure rules in the EU, US and proper reporting and transparency accountable for Canada. around EI revenues. Activities have the collection • Build capacity and raise awareness included training journalists and of taxes and in mining affected communities media campaigns, creating local civil royalties and civil society on their rights society networks to empower local regarding tax information EITI monitoring, and instituting (including ATI and RTI). (Tool: widespread civil society capacity- Information campaign) building campaigns. • Join OGP as a CSO member to learn from other CSO members Peru: A communication strategy and begin to engage government was developed to raise citizen on extractive industry-related social awareness of their rights, including accountability activities. Engage ATI. The communication strategy in South-South and North-South was implemented through multiple exchanges among CSOs. channels, such as radio programs, TV shows, and community visits. 40 Integrating Social Accountability Approaches into EI Projects REVENUE MANAGEMENT AND Link 4: Revenue Management and Allocation ALLOCATION Improved transparency and accountability on revenue management is critical to reducing corruption, ensuring good governance, and keeping civil society and citi- zens engaged and receptive to continuing EI operations in their countries and com- munities. When managed responsibly, revenues from EI operations have tremendous potential for poverty reduction. Transparency around EI revenue management and allocation also has a critical social dimension. Where extraction takes place, there is potential for conflict with commu- nities that bear the brunt of the social, economic, environmental, and health impacts of EI operations. When communities feel that EI benefits are not commensurate with the impacts they face, the results can be conflict and threats to EI operations. Once money has been transferred from companies to government, the question of how these funds translate into development gains for the country and affected com- munities are some of the most critical for the EI sector. The same questions that com- munities often ask, and that can be key elements of how EI revenues contribute—or fail to contribute—to sustainable development, can serve as entry points for account- ability mechanisms. These questions include: • What happens to the revenues companies pay governments? • Who has a say in how these funds are allocated? • How are intergovernmental transfers determined? • Who ensures that these funds are spent responsibly? • Are there earmarks on revenue sharing? • How can these funds be tracked through the national budget system? Key issues Countries typically have laws that determine how budget allocations from extractives revenues should be returned to impacted communities. Many countries require com- munity development agreements (CDAs) as a mechanism to channel some revenues back to local communities. However, in many countries, such financial allocations fail to make it back to the impacted communities. Where local-level allocations are made, local capacity to manage or absorb large revenue flows, and civil society capac- ity to demand accountability, may be low. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 41 Supportive legal frameworks are often useful to encourage the creation of funds and similar mechanisms for sustainable development, especially in EI-impacted commu- nities. Ghana’s Parliament approved the Petroleum Revenue Management Act, which created such funds. SA principles of transparency, accountability, and participation were embedded in the act (see Box 15). SA is a different way of doing things, so that citizens are more engaged in the entire process. Benefits are not just given to com- munities; communities are empowered to demand transparency, accountability, and participation. That helps make the benefits more sustainable. Box 15: Establishment of Funds for Sustainable Development— Good Legal Practice from Ghana Following unanimous approval by Parliament, Ghana’s president ratified the Petroleum Revenue Management Act in April 2011 (Act 815, hereafter the Act). This Act represents Ghana’s commitment to SA by making trans- parency a fundamental principle and by putting accountability structures in place through the establishment of the Public Interest and Account- ability Committee. In addition to this legal framework, the Act establishes numerous trust funds to better manage the allocation of EI revenues. The Act is significant for its establishment of the Petroleum Holding Fund, which pools EI revenues, including taxes and royalties, as well as the Ghana Stabilization Fund, which aims to lessen “the impact on or sustain public expenditure capacity during the periods of unanticipated petroleum revenue shortfalls.” The Act also establishes the Ghana Heritage Fund, which aims to provide “an endowment to support the development for future generations when the petroleum reserves have been depleted.” The establishment of this Act provided an opportunity for the government of Ghana to build numerous SA elements into the management of these funds. First, the Act made transparency a fundamental principle. It included a provision that confidentiality agreements should not limit access of EI information by Parliament or the Public Interest and Accountability Com- mittee. Furthermore, any information previously classified as confidential may become publicly available upon request three years after the date it was classified. The Act also states that Public Interest and Accountability Committee reports are to be published on the committee’s website. Second, the act promotes accountability by making the Investment Advi- sory Committee responsible for the oversight and reporting functions on the Ghana Petroleum Funds. This committee monitors and evaluates compliance of the government with the Act and provides platforms for discussion of development plans and independent assessments on the management and use of petroleum revenues. 42 Integrating Social Accountability Approaches into EI Projects Third, the Act emphasizes participation by mandating that the commit- tee consist of 11 members from civil society who are nominated by their institutions. The Act states that public meetings shall be held twice a year to discuss the reports with the general public. The Act also creates a plat- form for constructive engagement between the government, Parliament, and civil society for monitoring of government activities in management and allocation of EI revenues. A common challenge is when local governments with little experience and capacity to manage revenues begin receiving significant revenues from the central government. This often occurs when there is a combination of decentralization reforms and an influx of mining revenues. Local governments, often without any experience dealing with funds of this magnitude, become responsible for the effective and efficient use of these funds. For World Bank TTLs, the issue is finding a way to support national and local government efforts to manage such revenue flows. Box 16 illustrates an example from Madagascar of how this challenge was met.12 Box 16: Revenue Management and Allocation through Decentralization—Good Practice from Madagascar Madagascar is rich in various natural resources, including ilmenite, nickel, cobalt, coal, uranium, bauxite, diamonds, oil, and gas. The democratic transition in the early 1990s provided the context for decentralization. Despite the decentralization reforms, implementation stagnated, and Madagascar continued to experience large fiscal imbalances between cen- tral and subnational governments. Madagascar also lacked capacity to implement decentralization reforms and had a weak legal system to sup- port it.12 After the presidential election of December 2001, there was a renewed push for decentralization with support from the central government. Both poor mining-affected and nonaffected communities with weak local gov- ernment institutions started to receive large fiscal transfers. These transfers included government revenue from mining-related taxes and royalties. Under a pilot initiative on participatory budgeting, supported by the World Bank, three main activities supported local authorities in manag- ing their budgets: (1) establishment of project monitoring committees for elected community members to closely monitor the timelines and qual- ity of work undertaken by the local government; (2) disclosure of budget continues 12 Vaillancourt (2008). I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 43 Box 16: Continued information through information boards outside of city hall; and (3) host- ing of Accountability Meetings, forums where community members could express grievances and the mayor could respond to them. Through this participatory budgeting pilot, citizens were able to see budget information for the first time and were able to hold the local government accountable. The results from Madagascar indicate that revenue management and decision making on revenue allocation can be responsive and effectively executed with SA tools such as participatory budgeting. Although the initial achievements were promising, the 2009 coup d’état made continuation of this activity dif- ficult. Madagascar’s initial success encouraged other countries to incorporate SA. Tanzania, for example, is exploring a participatory budgeting pilot activ- ity on payments from mining companies directly to the local government to raise community involvement in decisions regarding EI revenues. Once funds to benefit local communities are created, the main SA challenges are to inform the public about the funds and their allocations and to monitor the use of funds to ensure that local people benefit from EI operations. Because there is a great deal of suspicion and misinformation about the use of funds to benefit local com- munities, using third parties to monitor the funds and publicize their findings helps allay these suspicions (see Box 17 for an example from Peru). Poor transparency and accountability of taxation and resource flows can frustrate both companies and civil society, with companies wanting to ensure that the public is aware of their payments to government, and civil society wanting proof of the benefits of extractive operations. There has been increasing emphasis on potential benefits that might accrue to the missing link in that equation—the government. Increasing transparency and accountability at local and national levels can help improve development outcomes of extractives operations and provide a clearer pic- ture of how EI revenues are spent. However, conflict with civil society—either by those who feel that the risks and vulnerabilities outweigh the benefits or those who feel they are getting an inadequate share of the benefits—are not eliminated by trans- parency and accountability. There are many challenges to accountability for how money enters and flows through government. Resource flows can be complex, detailed, and challenging for civil soci- ety to understand. Government may have limited incentives and capacity to make resource flows public, and there may be limited opportunities for citizen feedback and participation. Conversely, civil society capacity to follow complex revenue allo- cations is often plagued by poor transparency and dissemination of information on revenue flows. Numerous challenges and opportunities exist for supporting transpar- ency in revenue management and allocation at both the local and national levels. At the national level, capacity for revenue management may be low with high incentives 44 Integrating Social Accountability Approaches into EI Projects Box 17: Using the Media to Promote a Social Accountability Approach to Local EI Revenue Management From 2006 to 2011, the mining industry in Peru transferred over $4,774 million in royalties to municipalities located in key mining regions, in compliance with a 2004 mining canon law, but local officials have not always put these funds to the best use. In an IFC-supported project in Peru, independent monitoring mechanism (MIMs) were created to enable the communities to engage the local government on EI revenue issues. Each MIM partnered with five to seven local CSOs. The media played a key role helping promote transparency and accountability by following what happened with municipal investment and disseminating information to the public. To engage the media, MIMs produced publications on munici- pal governance and the progress of the Participatory Budget Monitoring Reports. MIMs also trained journalists on royalties and municipal invest- ment and conducted a media contest on municipal investment to moti- vate journalists to conduct their own research related to the good use of resources. During the life of the MIM Peru project, the media published over 13,000 media reports (257 media outlets) at no cost to the project. On average, the media published 172 articles (print, radio, or TV) based on information sent out by MIMs every month. This amounts to 21 articles per month per MIM, suggesting that the project was feeding the news practically every day. Most of the media mentions were focused on munici- pal investment, municipal management, citizen participation, and MIM activities. Responding to media requests and invitations, 22 representatives of MIM Boards of Directors participated in 183 media interviews as speak- ers for the project, helping put good use of resources in the local agenda. Source: Clarke, Karla and Fernando Ruiz Mier. 2011. Communications for the Ones Who Never Spoke: Running the MIM Marathon in the Peruvian Highlands. and low barriers to corruption. Transparency and accountability on national budgets may be weak. Without efforts to increase transparency, corruption or mismanage- ment may continue. Opportunities for social accountability SA tools such as public reporting of expenditures, public display of information, and public expenditure tracking can be used to promote transparency of financial trans- actions between the central government, local government, and private companies. Tools such as participatory monitoring and participatory budgeting can increase civil society engagement in revenue allocation. Participatory budgeting, such as by CBOs or in managing community development funds (CDFs), can be effective in incor- porating local community voices into local development planning in decentralized settings. Public dissemination of information on revenue allocation and opportuni- ties for holding governments accountable can be effectively disseminated through the I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 45 media. Box 18 lists some common entry points for introducing SA approaches in revenue management and allocation. Table 8 lists possible SA activities to improve transparency, accountability, and citizen participation in revenue management and allocation. These activities relate to four main challenges: (i) limited government capacity for public revenue management; Box 18: Entry Points for Social Accountability in Revenue Management and Allocation (Link 4) • Promote laws on revenue management that bring benefits to the public and embody SA. • Disclose revenue management information to the public. • Disclose relevant laws and regulations on revenue management and allo- cation to the public. • Build government capacity to disseminate revenue management information. • Consult or involve civil society on revenue management and allocation. • Use civil society and independent organizations to monitor revenue transfers. Table 8: Possible Social Accountability Activities for Revenue Management and Allocation Possible Activities Challenges (Approaches/Tools) Examples EI revenues do • Government adopts laws and Ghana: The Petroleum Revenue not benefit the other EI revenue management Management Act of April 2011 put general public mechanisms that benefit the general accountability structures in place public. through the establishment of the • Empower parliament and civil Public Interest and Accountability society to ensure oversight and Committee, which monitors and accountability of the government’s evaluates compliance of the government EI revenue management decisions. with the Act and provides platforms for discussion of development plans and independent assessments on the management and use of petroleum revenues. Peru: An MIM built community and CSO capacity to demand accountability at the local level. Through this mechanism, channels were created for the local population to communicate with municipal authorities to discuss mining revenues, municipal investments, and general service provision by municipal government. continues 46 Integrating Social Accountability Approaches into EI Projects Table 8: Continued Possible Activities Challenges (Approaches/Tools) Examples Limited • Build capacity of public agencies Ghana: The Public Interest and information to publicize revenue management Accountability Committee, which on revenue information. consists of representatives of civil management • Government actively disseminates society, is responsible for monitoring and demystifies revenue and overseeing revenue management. information from EI operations, This committee was established by the as well as expenditures and the 2011 Petroleum Revenue Management streaming of revenues, to the Act. The committee’s first annual report local level. (Tools: public reporting was issued in May 2012. of expenditure, public display of information, information campaign, budget literacy campaigns) Weak system of • Build capacity of local governments Indonesia: In 1998, Indonesia decentralization: in revenue collection and implemented decentralization reform, lack of clear lines management. but this was not coordinated with the of accountability • Disclose revenue management and Mining Code. In 2009, Parliament between central, allocation laws and regulations to finally passed a new mining law regional, clarify roles and responsibilities of that clearly corresponded to the and local each public agency. (Tools: public decentralized system on collection and governments display of information, information allocation of mining revenues. campaign) • Support participatory decision Afghanistan: When it came to making on revenue management transactions for local community and allocation at local and national development (allocation of mining levels, for example, through revenues), the Aynak mine did participatory budgeting. (Tools: not have clear guidelines regarding participatory planning, participatory institutions responsible for collection budgeting) and disbursement of revenues. To resolve this issue, the Ministry of Mines prepared the Community Consultation Guidelines and Framework to support mining-sector policy and provide clarification of key roles and responsibilities. Mali: Tensions between mining companies and local communities were rising because the government lacked capacity to manage and transfer tax revenues from the mining companies for community development. To resolve this, with support from U.S. Agency for International Development (USAID), the Sanso Morila Mine Alliance was created to strengthen transparency, produce a model development action plan, and build capacity of local governments to manage revenues. CSOs were deeply involved in developing the action plan. continues I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 47 Table 8: Continued Possible Activities Challenges (Approaches/Tools) Examples Limited capacity • Build CSO capacity on Peru: In 2005, the IFC began a of civil society understanding revenue allocation pilot initiative to promote SA. It to monitor and formulas, monitoring capacity, was launched to help ensure that analyze revenue and data and information analysis, payments made to the authorities allocation and including budget analysis and by a client (a mine) could be used management how to identify bottlenecks and/ in a way that benefited the local from national to or corruption. (Tools: budget literacy population. The project focused on local levels campaigns) providing the information, tools, • Establish an independent and training to facilitate a more monitoring institution on revenue open, informed discussion of how management and allocation. resources are invested. The project (Approach: third-party monitoring) established operational units made up • Support citizen reporting and of representatives from 30 well-known monitoring mechanisms on revenue local CSOs to ensure accountability management and allocation to and effective results. start dialogue with citizens and civil society. (Tools: community Congo: The PWYP coalition examined monitoring, community oversight, the country’s health budgets and grievance redress mechanism, public followed oil revenue money to see hearings) whether funds were being disbursed to • Encourage CSOs to follow the the projects and whether projects were financial flow from the extractive being executed. PWYP Congo revealed industries down to the local that in many cases, the money was not level, and publish the results in reaching its intended destination and multiple forums (e.g., newspaper, that projects were not being properly website, radio shows, etc.) to executed. reach the general public. (Tools: Sierra Leone: In May 2012, one of public expenditure tracking survey, the CSO representatives contributed information campaigns) an article to a national newspaper on • Encourage the disclosure of the 2012 Citizens Budget. It analyzed, financial information in an editable interpreted, and posed questions on format to enable civil society and the national budget, which included EI citizens to use the data. revenues. Limited • Build capacity of local governments Madagascar: Participatory budgeting uptake by local to enhance their ability to was introduced to allow citizens to community effectively engage citizens in participate in the decision-making voices in inclusive decision making. process of budget allocation. Budgetary determining • Promote participatory budgeting, information was posted on the local budget participatory decision making, and information board outside of city hall, allocations community management for citizen providing citizens access to budget voices to be effectively incorporated information. Additionally, citizens have into local development decision regular opportunities to ask the mayor making. questions and for the mayor to respond • Conduct awareness raising and through city-hall types of meetings. community outreach activities for Similar activities have taken place in citizens to better understand their the DRC, Cameroon, the Dominican rights, legal frameworks, fiscal Republic, and Brazil. mechanisms, and development plans. (Tools: information campaign, budget literacy campaigns) 48 Integrating Social Accountability Approaches into EI Projects (ii) limited government capacity to collect and publicize information on revenue management; (iii) weak system of decentralization and nonuniform legal systems and lack of clear lines of accountability between central, regional, and local governments; (iv) limited capacity of civil society to monitor and analyze revenue allocation and management from national to local levels; and (v) limited uptake by local community voices in determining local budget allocations. Table 8 illustrates how SA approaches can address these challenges. It also provides examples of these approaches. IMPLEMENTATION OF SUSTAINABLE DEVELOPMENT Link 5: Implementation of Sustainable POLICIES AND Development Policies and Projects PROJECTS The final link of the EI value chain relates to the social, environmental, and fiscal policies and investments that translate EI operations into sustainable development for the communities, countries, and companies involved. On the government side, this refers to decisions about how EI revenues are invested—for example, public financial management policies, environmental management and remediation, pub- lic investment decisions, and community development projects. For companies, this link may relate to the corporate social responsibility programs they support. The suc- cess of these policies and projects to contribute to long-term sustainable development depends on their ability to recognize and respond to the sustainable development challenges they face, obtain the participation and support of affected communi- ties, and integrate with existing development plans. SA tools can play a large part in achieving this. For communities, this refers to having a voice in how funds from EI projects are used to support sustainable local development. Challenges for accountability The challenge is to reach a shared vision for “sustainable development” and oppor- tunities at the national and local levels for people to participate in the formulation of these policies and projects. Even defining “impacted communities” can be a chal- lenge. Many groups will have an incentive to claim impacts, but it is critical to ensure that those who are genuinely impacted have a say in sustainable development policies and projects. Communities may not know their rights, especially in terms of local development funds to which they are entitled, or be skeptical that EI will bring local benefits such as jobs and development funds. With jobs and other benefits at stake, there can be tension and even conflict. Opportunities for accountability SA can easily be integrated into this link because many activities deal directly with communities and thereby benefit from community participation. For example, partic- ipation can be integrated into budgeting processes, environmental management and remediation, public investment decisions, and especially community development programs. Participatory monitoring that gives communities access to information I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 49 Box 19: Entry Points for Social Accountability in Sustainable Development Policies and Projects (Link 5) • Use open consultations to set priorities for sustainable development. • Use participatory decision making in designing national and community development plans. • Involve citizens and civil society in the management of community development funds. • Use citizens, civil society, and independent organizations to monitor the management of development funds. • Disclose development policies and reports to the public on the manage- ment of development funds. and empowers them to monitor how policies and projects are being implemented can be particularly effective in activities under this link. Box 19 lists some common entry points for introducing SA approaches in sustainable development projects for mining-affected communities. Examples of social accountability in sustainable development policies and projects There are many examples of World Bank–assisted projects using SA mechanisms to address the challenges of sustainable development policies and plans concerning mining-affected communities. For example, many stakeholders—national and local governments, civil society, and the private sector—have participated in the establish- ment of a CDF in the Lao People’s Democratic Republic (see Box 20). The CDF is Box 20: Moving toward the Creation of a Participatory Community Development Fund in Laos The mining sector in Laos has developed rapidly since 2003. Estimated annual mining revenues have increased from US $10 million before 2003 to an estimated US $1.3 billion in 2011. Both large- and small-scale operations bring significant impacts to affected communities, both posi- tive (e.g., employment and other economic activities) and negative (e.g., environmental degradation and the loss of livelihoods). In response, the government is implementing a participatory development planning pro- cess with support from the World Bank and the Australian Agency for International Development (AusAID). Through the project, several important and innovative steps have ensured benefit sharing at the community level. The most important of these, in 50 Integrating Social Accountability Approaches into EI Projects the context of the CDF, is the creation of a multiple-stakeholder working group that includes several ministries, local authorities, and company rep- resentatives. Development partners serve as observers. The creation of this group allowed the Lao mining sector to respond cohesively to innovative activities, including the Gender Assessment of Artisanal and Small-Scale Mining in the Lao People’s Democratic Republic (PDR), and evolving global standards for CDFs. As a result, the Lao PDR government has made gender inclusion in the mining sector a national strategic priority, and women’s groups (e.g., unions) now have a platform to voice their con- cerns on gender-sensitive and socially inclusive development in the mining sector. The government has hosted a conference and a workshop to discuss formalizing the CDF procedure for the mining sector and to learn from international practices. In 2014, Implementing Rules and Regulations were drafted to define the overall objectives, modalities, and principles of accountability for two different types of mining CDFs. attempting to achieve sustainable development through (1) encouraging commu- nity decision making and implementation of development projects, (2) improving community–government interaction by managing community development projects and activities, and (3) creating social capital and improving local livelihoods. Experi- ence in establishing this CDF is expected to be applied to future CDFs. SA approaches can also help monitor CDF implementation. In the DRC, CSOs monitor companies’ compliance with their obligation to fund a social development fund. They also monitor how the fund is managed and how expenditure decisions are made (see Box 21). Monitoring is useful to the companies because it assures the com- panies that the revenues they provide local communities lead to the expected benefits. Extractive industries provide many other benefits to local communities other than development funds. They generate economic opportunities. For many projects, one of the most highly valued benefits is jobs. SA approaches help inform local people about job opportunities, give them a voice in how jobs are allocated, and enable them to monitor EI company commitments regarding jobs for local people. Box 22 provides an example from Burkina Faso, where a CSO helped monitor company compliance with targets for jobs for local people and informed local communities of job opportunities with the mining company. Where there are mineral deposits for commercial mining, often there are artisanal and small miners (ASMs) as well. SA approaches can be useful in providing support to ASMs, another form of supporting employment of local people. An example from Uganda not only helped support ASMs, but greatly increased the number of licenses awarded to them. It also supported the piloting of safer, more environmental friendly, and more profitable income-generating activities through a small grants program (see Box 23). I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 51 Box 21: Monitoring Social Development Funds in the Democratic Republic of the Congo In the DRC, the government has published dozens of mining contracts. CSOs are using this opportunity to monitor company compliance with social investment regulations, and to explore the implications of this increased transparency. Action against Impunity for Human Rights (ACIDH), working with the Platform of Civil Society Organizations Working in the Mining Sector (POM), is monitoring not only payment into social development funds at the Tenke Funkurume mine, but also how these funds are used. Mining company operators at the copper and cobalt mine (including Freeport McMoRan, Lundin Mining, and Gecamines) were found to be in compliance of paying 0.3 percent of net proceeds into a social development fund to benefit local communities. However, despite the fact that the requisite funds were paid, and further tracking of these payments revealed that they were spent on projects like schools, bridges, and wells, many citizens who were meant to be benefitting actually did not know about how the fund was managed and how decisions were made. By bringing this to light with the company, POM and ACIDH’s monitor- ing enabled the company to identify a gap in information sharing, and to undertake to better engage with the community on their obligations and activities. Source: Heller, Patrick. 2013. Putting Contract Transparency to Work. Open Contract- ing blog. Box 22: Monitoring Local Content in Burkina Faso Local content in the extractive industries refers to the degree to which investors use local labor and purchase goods and services from local firms. What companies pay for local procurement of goods and services can sig- nificantly outweigh what they pay to governments in taxes and fees, thus reflecting a critical aspect of how extractives industries contribute to local revenues and development. As such, companies, governments, and civil society have all paid increasing attention to this issue over the last decade, and many countries have adopted new policies and legislation and started targeted initiatives to promote local content. To ensure that the maximum benefit from these local procurement opportunities are reaching local communities, civil societies in many countries have started demanding increased transparency regarding procurement decisions by companies and the publishing of local procurement plans, and several countries have included aspects of local content in their EITI reports. In some countries, civil societies have launched initiatives to monitor hiring and procurement practices of mining companies. 52 Integrating Social Accountability Approaches into EI Projects In Burkina Faso, local contracts and national regulations require mining companies to hire 75% Burkinabe staff. Local CSOs are taking a proactive role in monitoring local hiring to ensure compliance with these regula- tions. Organisation pour le Renforcement des Capacités de Développe- ment (ORCADE) found that the companies managing the Essakane and Kalsaka (including IAM Gold and Cluff Gold) have met this obligation, although skilled and managerial positions are still filled predominantly by expatriates. Thus, while monitoring and information dissemination around these obligations did help improve public awareness around the project, the gaps in senior management that ORCADE identified also led to recommendations to government for investments in long-term skills training. ORCADE’s monitoring project also highlighted gaps within the government’s own understanding of mining contracts, and government’s own ability to enforce local procurement rules. So the project helped not only to shed light on procurement compliance, but to generate dialogue, create policy recommendations, and build accountability capacity. Source: Heller, Patrick. 2013. Putting Contract Transparency to Work. Open Contract- ing blog. Box 23: Support to Artisanal Miners in Uganda Between 2003 and 2011, the Uganda Sustainable Management of Mineral Resources Project trained officials, miners, and communities to strengthen governance, transparency, and capacity in the management of mineral resources. Its particular emphasis on the improvement of ASMs and commu- nity development in mining areas transformed the lives of miners and their families by promoting socially and environmentally sound development. This helped lead to the creation of a government strategy to support the pre- viously ignored ASM sector. An outreach and training program aimed to raise ASMs’ awareness of regulatory provisions, mining rights, and environmental and technical issues and to encourage the creation of mining associations and cooperatives to formalize mining activities. Community members received small grants to pilot safer, environmentally friendly, and more lucrative small-scale income-generation practices in mining communities. The grants scheme laid the foundations for mainstreaming ASMs into national and local economic development. Local governments in mining areas began to collect revenue from ASM operations, which is expected to provide an incentive for mining to be integrated into district and subcounty development plans. Lost royalties from informal, unlicensed ASM operations had been estimated at up to US $3.6 million in 2011. The project resulted in a dramatic increase in the number of licenses issued. Against a baseline of 100 and a target of 300, more than 950 ASM licenses were issued from 2005 to 2011. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 53 Table 9 suggests possible SA activities to improve transparency, accountability, and citizen participation in sustainable development projects for mining-affected com- munities. These activities address four main challenges: (i) lack of consensus on what “sustainable development,” “impacted,” or “affected” communities means, possibly leading to conflict; (ii) lack of understanding of rights at the local level; (iii) com- munity skepticism that extractive industries will bring local benefits because of insuf- ficient information; and (iv) tensions around jobs in EI operations reserved for local people. It also offers suggestions on how to support ASM components. Table 9 dem- onstrates how SA approaches can address these challenges. It also provides examples of these approaches. Table 9: Possible Social Accountability Activities for Sustainable Development Projects Possible Activities Challenges (Approaches/Tools) Examples Lack of consensus • Use open consultations, with Latin America (Bolivia, Colombia, on what efforts to ensure gender equity Ecuador, Peru, and Venezuela): “sustainable and include all community Several countries in Latin America development” members, to set priorities for came together to form a multiple- means, leading to sustainable development. stakeholder discussion forum, called conflict • Use participatory decision COICA (Coordinadora Indígena de la making with government Cuenca Amazónica), where activities (national to local), citizens, civil related to the oil and gas industry society, EI companies, and other and sustainable development were stakeholders (e.g., donors) to discussed. Priority areas were identified reach consensus. via consultations with indigenous • Conduct community outreach peoples, including industry activities, and advocacy activities on EI participatory monitoring of social operations to ensure informed and environmental impacts of the participatory decision making. industry, and sustainable development • Promote a multiple-stakeholder at the local level. Through consensus approach (e.g., civil society, with multiple actors, COICA community members, private provides a platform to develop mutual sector, and national and local understanding and trust-based governments) in establishing a relationships among stakeholders CDF. Madagascar: In the community of Anosy, Madagascar, CommDev is supporting a project to bring together government, communities, civil society, and private companies for the creation of a community development organization, thereby enabling local stakeholders to determine what sustainable development means for them. continues 54 Integrating Social Accountability Approaches into EI Projects Table 9: Continued Possible Activities Challenges (Approaches/Tools) Examples Lack of consensus • Keep the process of determining Lao PDR: Determination of “mining on which “affected communities” affected communities” is under communities are transparent, using information discussion using a participatory “impacted” or and data disclosure and measures mechanism, with the multiple- “affected” ensuring that consultations are stakeholder working group at its inclusive. center. This is one of the processes • Introduce participatory decision created by the CDF. making to reach consensus on “affected communities.” Lack of • Publicize local-level rights in a Sierra Leone: The Justice for the understanding of way that citizens can access and Poor (J4P) program, along with the rights at the local understand. government, developed a Diamond level • Conduct community outreach Area Community Development and advocacy activities to inform Fund (DACDF) handbook to raise community members on their awareness of the laws and entitlements rights and resources available of community members. Outreach to them, including land and also was conducted via community livelihood rights, development radio. plans, and complaint-handling mechanisms. (Tools: information campaign, citizen charter) • Utilize information communications technology, including community radio and television shows, for community outreach and advocacy. Community • Promote legal frameworks Lao PDR: A CDF was created skepticism about ensuring that funds intended for through a multiple-stakeholder the local benefits local communities benefit them. working group that includes several of EI operations • Use participatory decision ministries, local authorities, and making in designing national company representatives. and community development plans. (Tools: participatory DRC: The ACIDH is collaborating planning, participatory budgeting, with the POM to track the payment community management) and use of social development funds • Use citizens, civil society, and at the Tenke Funkurume copper and independent organizations to cobalt mine. The POM and ACIDH monitor the management of found that the company complied development funds. (Tools: with this obligation and that the funds community monitoring, had been spent on tangible projects— community scorecards, third-party schools, bridges, wells—that have monitoring) benefitted the mine’s neighbors. • Disclose reports to the public on the management of development funds. continues I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 55 Table 9: Continued Possible Activities Challenges (Approaches/Tools) Examples Tensions • Through laws and regulations, Ghana: The 2006 Minerals and around jobs in define what “local procurement” Mining Act states that the holder of a EI operations means and the responsibilities of mineral right should give preference reserved for local the government, EI companies, to materials, products, and service people and license holders on local agencies of Ghana and employment hiring and procurement. preferences to citizens of Ghana. The • Disseminate and disclose laws scope of local products and service and regulations concerning agencies is also provided. “local procurement and hiring.” • Publish local procurement plans. Burkina Faso: Three local CSOs • Ensure that jobs are posted monitor the hiring of national in local languages, that citizens by the Essakane and Kalsaka procurement and hiring projects. The companies are required procedures are clear, and to have staffs that are 75 percent that there are mechanisms Burkinabe. CSOs reported that the for communities to provide companies have complied with this feedback and complaints. (Tools: obligation. Quantifying and sharing public display of information, this information is improving public complaint-handling mechanism) understanding of the project. • Government monitors the Peru: Under the entrepreneurial implementation of local capacity-building program provided procurement and hiring by EI through the CDF (Asociación Los companies and discloses reports Andes de Cajamarca: ALAC), various to the public. trainings are provided (e.g., on • Encourage community jewelry, textile handcrafts, various participation in the selection food products, bio-commerce with process for unskilled workers for medicinal plants). From the launch the EI project. of the CDF in 2004 through 2008, • Provide vocational and skills the project succeeded in generating training to the local population over 16,000 new jobs, in adopting and to those who are displaced best practices, and in creating new as a result of EI activities technologies by over 14,000 people, for both mining-related and among which 2,000 people developed nonmining-related activities to new productive activities. Vocational diversify their livelihoods. training provided a chance for the local communities to diversify livelihoods. Support to ASMs • Provide extension services Uganda: The Uganda Sustainable that include training on Management of Mineral Resources accountability and transparency Project trained officials, miners, (of regulations, of licenses, of and communities to strengthen processes, etc.), combined with governance, transparency, and mechanisms so that ASMs capacity in the management of can provide feedback on local mineral resources. It focused on services. the improvement of ASMs and • Establish small grants programs community development in mining that build good governance and areas. This helped drive the creation of local-level accountability into a government strategy to formalize and their design. support the previously ignored ASM sector. 56 Integrating Social Accountability Approaches into EI Projects Conclusion This note has provided many examples of how SA can improve the imple- mentation and outcomes of EI projects. SA is a powerful instrument for development, more effective institutions, and better projects. SA can reduce project risk and create more sustainable development outcomes. Particu- larly in countries with developed or potential mineral wealth, transparency, accountability, and citizen participation are key factors in how those resources contribute to growth and poverty reduction. Although many examples have been provided, task teams and other stakeholders will need to seek out addi- tional ways to integrate SA in their projects. The annexes provide additional resources and ideas for a deeper understanding of SA and how it can improve EI projects and their outcomes. SA approaches are not a panacea. They need to be complemented with supply-side measures by government and EI companies. SA approaches have to be carefully tailored to the context because many methods will not work where there is insufficient capacity, political commitment, incentives to use SA approaches, and other dimensions of an enabling environment. SA approaches have costs and risks as well. SA can create tensions between communities and government. Care must be taken in providing necessary support before SA can be attempted. SA may not be as effective when govern- ments lack the capacity or financial means to meet citizen and community demands, even if they want to be responsive. Despite the costs and risks, SA can be a valuable aspect of World Bank operations. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 57 References Abraham, Arun, and Rodolfo B. Santos Jr. 2010. Towards a Research Framework for Mainstreaming Social Accountability in the Oil, Gas and Mining Industries of Selected East Asia Pacific (EAP) Countries. Affiliated Network for Social account- ability in East Asia and the Pacific. Acosta Mejia, Andres. 2010. Annex 4: Natural Resource Governance: Review of impact and effectiveness of transparency and accountability initiatives. Background paper for Rosemary McGee and John Gaventa, Synthesis Report: Impact and Effective- ness of Transparency and Accountability Initiatives. London, UK: Open Society Foundation, Transparency and Accountability Initiative. Balbo Di Vinadio, Tommaso, Priyanka Sinha, and Paramjit Sachdeva. 2012. Strength- ening Inclusive Stakeholder Ownership through Capacity Development. Washing- ton, DC: World Bank Institute. Centre for Environment and Development (CED) and Network Fighting Hunger in Cameroon (RELUFA). 2013. “Monitoring Local Content and Fiscal Obliga- tions of Mining Companies in Cameroon: Case of the Diamond Mining Project of Cameroon and Korea Mining Incorporation Mobilong, East Cameroon.” Clarke, Karla and Fernando Ruiz Mier. 2011. Communications for the Ones Who Never Spoke: Running the MIM Marathon in the Peruvian Highlands. Washing- ton, DC: World Bank. Economic Commission for Africa. 2002. “Compendium on Best Practices in Small- Scale Mining in Africa.” “Editorial: Flawed Mining Permits.” January 18, 2012. Jakarta Post. Eftimie, Adriana, Katherine Heller, and John Strongman. 2009a. Gender Dimensions of the Extractive Industries: Mining for Equity. Washington, DC: World Bank. Eftimie, Adriana, Katherine Heller, and John Strongman. 2009b. Mainstreaming Gender into Extractive Industries Projects: Guidance Note for Task Team Leaders. Washington, DC: World Bank. Ghana Minerals and Mining Act (Act 703). Government of Ghana, 2006. Ghana Petroleum Revenue Management Act (Act 815). Government of Ghana, 2011. GOXI. EI Sourcebook. 2015. Washington, DC: World Bank. Heller, Patrick. 2013. Putting Contract Transparency to Work. Open Contracting blog. 58 Integrating Social Accountability Approaches into EI Projects International Finance Corporation and Engineers against Poverty. 2011. “A Guide to Getting Started in Local Procurement: For Companies Seeking the Benefits of Linking with Local SMEs.” International Finance Corporation. 2007. Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets. ––––. 2010. Strategic Community Engagement: A Good Practice Handbook for Compa- nies Doing Business in Emerging Markets. ––––. 2013. Lessons of Experience—Peru LNG: A Focus on Continuous Improvement. International Monetary Fund. 2007. “Guide on Resource Revenue Transparency.” Kheyfets, Igo, Massimo Mastuzzi, Dino Merotto, and Lars Sondergaard. 2011. “ECA Knowledge Brief: A New Data Tool to BOOST Public Spending Efficiency.” Washington, DC: World Bank. Malena, Carmen, and Mary McNeil. 2010. Demanding Good Governance: Lessons from Social Accountability Initiatives in Africa. Washington, DC: World Bank, 2010. Mayorga Alba, Eleodoro. 2009. “Extractive Industries Value Chain: A Comprehen- sive Integrated Approach to Developing Extractive Industries.” Working Paper, World Bank, Washington, DC. McMahon, Gary. 2010. The World Bank’s Evolutionary Approach to Mining Sector Reform. Extractive Industries for Development Series #19, World Bank, Wash- ington, DC. Natural Resource Governance Institute. 2010. “Natural Resource Charter.” ––––. 2014. “Final Analysis of Outcomes from MDTF Support to NRGI on Civil Society Engagement In EITI.” ––––. n.d. “Using EITI for Policy Reform: Natural Resource Governance Institute Guide to the EITI Standard.” http://www.resourcegovernance.org/eitiguide/ Rosenblum, Peter, and Susan Maples. 2009. Contracts Confidential: Ending Secret Deals in the Extractive Industries. Revenue Watch Institute. Scott, Jen, Rose Dakin, Katherine Heller, and Adriana Eftimie. 2013. Extracting Les- sons on Gender in the Oil and Gas Sector: A Survey and Analysis of the Gendered Impacts of Onshore Oil and Gas Production in Three Developing Countries. Wash- ington, DC: World Bank. Sheldon, Christopher Gilbert, Alonso Zarzar Casis, Georg Caspary, Verena Seiler, and Fernando Ruiz Mier. 2013. Innovative Approaches for Multi-Stakeholder Engagement in the Extractive Industries. World Bank, Oil, Gas, and Mining Unit Working Paper, Washington, DC. Smith, Erin, and Peter Rosenblum. 2011. Government and Citizen Oversight of Min- ing: Enforcing the Rules. Revenue Watch Institute. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 59 Stanley, Michael, and Ekaterina Mikhaylova. 2011. “Mineral Resource Tenders and Mining Infrastructure Projects Guiding Principles, Case Study: The Aynak Cop- per Deposit, Afghanistan.” Washington, DC: World Bank. Tayou, Emma Tarrant. 2012, May 18. Ghana Oil Report Sets New Standard for Accountability. NRGI blog. USAID. 2010. Alliance Industry Guide: Extractives Sector. USAID. Vaillancourt, François. 2008. “Decentralization in Madagascar: A String of Unfin- ished Races.” International Studies Program Working Paper 08-37, Georgia State University, Atlanta, GA. Wall, Elizabeth, and Remi Pelon. 2011. Sharing Mining Benefits in Developing Coun- tries: The Expereince with Foundations, Trusts, and Funds. Washington, DC: World Bank. Ward, Bernie, John Strongman, Adriana Eftimie, and Katherine Heller. 2011. Gender-Sensitive Approaches for the Extractive Industry in Peru: Improving the Impact on Women in Poverty and Their Families—Guide for Improving Practice. Washington, DC: World Bank. World Bank. 2007. Angola: Oil, Broad-based Growth, and Equity—A World Bank Country Study. Washington, DC: World Bank. ––––. 2008. Sierra Leone Mining Sector Reform: A Strategic Environmental and Social Assessment. Washington, DC: World Bank. ––––. 2010. Mining Foundations, Trusts and Funds: A Sourcebook. Washington, DC: World Bank. ––––. 2011a. “Briefing Note 1: Community Development in the Lao Mining Sec- tor.” Washington, DC: World Bank. ––––. 2011b. “How-To Notes: Feedback Matters: Designing Effective Grievance Redress Mechanisms for Bank-Financed Projects Part 1: The Theory of Griev- ance Redress.” Washington, DC: World Bank. ––––. 2011c. “How-To Note: Feedback Matters: Designing Effective Grievance Redress Mechanisms for Bank-Financed Projects Part 2: The Practice of Griev- ance Redress.” Washington, DC: World Bank. ––––. 2011d. “How-To Notes: How, When, and Why to Use Demand-Side Gover- nance Approaches in Projects.” Washington, DC: World Bank. ––––. 2011e. “Strengthening the World Bank’s Engagement on Demand for Good Governance: DFGG Companion Piece on the GAC Strategy II.” Washington, DC: World Bank. ––––. 2012a. “GOXI Innovation Stories Case Studies: Changing Lives of Artisanal Miners and Mining Communities in Uganda.” Washington, DC: World Bank. ––––. 2012b. “GOXI Innovation Stories Case Studies: Community Education and Dialogue to Assist in the Implementation of a National Diamond Mining Ben- efit Sharing Fund.” Washington, DC: World Bank. 60 Integrating Social Accountability Approaches into EI Projects ––––. 2012c. “GOXI Innovation Stories Case Studies: Strategy for Gender and Socially Inclusive Development in the Lao Mining Sector.” Washington, DC: World Bank. ––––. 2012d. “How-To Notes: Using Demand Side Governance Approach to Iden- tify and Manage Risks in Projects.” Washington, DC: World Bank. ––––. 2012e. “Increasing Local Procurement by the Mining Industry in West Africa, Road-test version.” Washington, DC: World Bank. ––––. 2012f. “Strengthening Governance: Tackling Corruption, The World Bank Group’s Updated Strategy and Implementation Plan.” Washington, DC: World Bank. ––––. “The World Bank Group in Extractive Industries 2011 Annual Review.” Washington, DC: World Bank. ––––. 2013. “How-To Notes: Participatory and Third Party Monitoring in World Bank-financed Projects: What Can Non-State Actors Do?” Washington, DC: World Bank. ––––. 2014a. Strategic Framework for Mainstreaming Citizen Engagement in World Bank Group Operations: Engaging with Citizens for Improved Results. Washington, DC: World Bank. ––––. 2014b. “Investment Project Financing Project Preparation Guidance Note.” Washington, DC: World Bank. ––––. 2014c. “Results Framework and M&E Guidance Note.” Washington, DC: World Bank. ––––. n.d. “Small Stories: 12 Stories about Small-Scale Mining.” World Bank, Com- munities and Small-Scale Mining. Washington, DC: World Bank. World Bank Social Accountability E-Guide. Chad & Cameroon: Petroleum Develop- ment & Pipeline Construction: Independent monitoring through the Independent Advisory Group (IAG). World Bank Social Accountability E-Guide. Peru: Community monitoring of Peru’s Natural Gas Pipeline Project. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 61 Annex 1. Checklist for Designing and Implementing Social Accountability Activities Step 1: Identify and prioritize social accountability issues, concerns, and opportunities • Identify the governance concerns and opportunities associated with the project • Identify project beneficiaries and affected communities • Identify incentives and disincentives (sanctions/rewards) to achieving social accountability goals • Identify potential entry points for social accountability activities (in conjunc- tion with Step 2) Step 2: Diagnose the political, legal, and social context for social accountability activities • Conduct stakeholder mapping and analysis of their capacities • Identify individuals and organizations within government, civil society, media, academia, and the private sector who can support, facilitate, or oppose social accountability activities • Review legal framework (e.g., access to information, legal status of CSOs) • Assess political, social, and cultural conditions for citizen engagement • Review existing social accountability activities and their experience 62 Integrating Social Accountability Approaches into EI Projects Step 3: Select and sequence appropriate social accountability tools given the context • Consult stakeholders on choice of social accountability activities and provide them feedback • Determine extent of government cooperation and civil society involvement • Assess attitudes and capacities of government and CSOs on social account- ability activities • Tailor social accountability activities to local context • Assess technical and financial requirements of selected social accountability activities • Validate initial design Step 4: Decide on implementation modalities for social accountability activities (actors, budgets, timing) • Identify funding—project funds, trust funds, or other sources • Match the sequencing of social accountability activities with project implementation • Develop communication strategy to support social accountability activities • Pilot social accountability activities, monitor, and adjust • Expand after pilot testing • Implement and document social accountability activities • Include capacity building for both government and civil society Step 5: Decide on follow-up and institutionalization (M&E, sanctions, incentives) • Integrate social accountability M&E with project M&E (including social accountability indicators) • Monitor the implementation of social accountability activities • Include citizen and CSO feedback mechanisms • Assess impact of social accountability activities • Disseminate and validate findings with stakeholders • Organize networking, peer learning, and experience sharing of social account- ability implementation experience I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 63 Annex 2: Sample Indicators for Social Accountability Type of Social accountability Activity Sample Indicators Information dissemination • Contracts, licenses, leases, bidding criteria, bid evaluation processes, factors in winning a license, winning bids, laws, (Mechanisms: public regulations, etc. are made public (yes/no) disclosure of information, • Procurement plans, contracts, and tender documents are made information-distribution public (yes/no) and awareness-raising • Taxes, royalties, and allocation of EI revenues are made public campaigns, ATI laws, open- (yes/no) data activities, etc.) • Transparency and disclosure of information part of World Bank lending conditions (yes/no) • Standards proscribed by ATI or RTI laws are applied to extractive industries (yes/no) • Inspection and regulatory enforcement monitoring results are disclosed (yes/no) • Local-level rights are publicized in a way that citizens can access and understand (yes/no) • Awareness-raising and community outreach activities for citizens (yes/no) • Citizens are aware of project activities and impacts (yes/no) Grievance Redress • Grievance redress system established to address citizen complaints (yes/no) • Citizens filed grievances/complaints (number) • Registered grievances that are addressed (percentage) • Grievances addressed within stipulated time period (percentage) • Average time required to resolve complaints (days) • Complainants satisfied with response and grievance redress process (percentage) • Periodic reports on grievance redress mechanism results published (yes/no) 64 Integrating Social Accountability Approaches into EI Projects Type of Social accountability Activity Sample Indicators Consultation • Civil society consulted when drafting EI legal frameworks and regulations (yes/no) (Mechanisms: focus groups, • Citizens consulted during project implementation (number) consultations, surveys, etc.) • Citizens consulted reporting satisfaction with consultation process (percentage scoring satisfied or higher) • Participants in consultations who are from vulnerable and marginalized groups (e.g., women, poor, youth, disabled, indigenous peoples) (percentage) • Civil society is consulted on social and environmental impact assessments (yes/no) Empowering Citizens and • Citizens that feel that EI operations address their concerns Communities (percentage) • Representatives in community-based decision-making and (Mechanisms: participatory management structures who are from the vulnerable or planning, citizen/user marginalized beneficiary population (percentage) membership in decision- • Participation rate of the poor, vulnerable, and women in making bodies, etc.) planning and decision-making meetings (percentage) • Participatory decision making on revenue management and allocation (yes/no) • Community role in allocating community development funds (yes/no) Beneficiary Feedback • Proportion of total beneficiaries who provided feedback (percentage) (Mechanisms: satisfaction • Share of feedback providers who are from vulnerable and surveys, citizen/community marginalized or other target groups (e.g., geographic group) report cards, social audit, (percentage) SMS/online feedback, etc.) • Actions taken by program/project managers based on user/ beneficiary feedback (yes/no) • Programs/institutions collecting feedback publish reports on feedback received and how this feedback has been used (yes/no) Citizen and Third-Party • Independent oversight of EI operations and regulations (yes/no) Monitoring, Evaluation, • Citizens and/or CSO monitoring of EI contracts, revenue and Oversight allocation, etc. (yes/no) • Civil society and community members participate in, or (Mechanisms: social monitor, EI operations (yes/no) audits, public expenditure • Findings of citizen-led monitoring are made public tracking surveys, third-party (yes/no) monitoring, etc.) • Forum for validating and providing feedback on monitoring results (yes/no) • Use of feedback provided by independent, citizen, and CSO monitoring (yes/no) • Monitoring committees trained in participatory monitoring (percentage) • Beneficiaries satisfied with monitoring (percentage) • Authorities act on issues identified by the monitoring/oversight activities (yes/no) • Changes to policies and project activities as a result of citizen monitoring (yes/no) I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 65 Annex 3. Sources of Information on Social Accountability in Extractive Industries World Bank Resources Communities and Small-Scale Mining (CASM): Launched in 2001, CASM is a global networking and coordination facility with a stated mission to “reduce poverty by improving the environmental, social and economic performance of artisanal and small-scale mining in developing countries.” CASM is housed at World Bank head- quarters in Washington, DC. Extractive Industry Task Group (EITG): The purpose of the EITG is to improve knowledge sharing, coordination, and dissemination within the World Bank Group and among external clients and partners. A key objective of the EITG is to summa- rize emerging industry trends and to assess where new understandings are warranted. Governance and Anti-Corruption (GAC): Via the GAC Knowledge and Learn- ing website, resources and information from all departments and units engaged in the World Bank Group’s GAC Strategy and activities are shared. Among them are Demand for Good Governance and GAC in Natural Resource Management. International Finance Corporation—Oil, Gas & Mining: The mission of this team is to help developing countries and communities realize sustainable economic benefits from natural resources. Sharing in Governance of Extractive Industries (GOXI): GOXI is a space to share, learn, and connect for action toward greater accountability and, in turn, better devel- opment outcomes of the extractive industries in Africa. It is supported by the World Bank Institute and its partner institutions. External Resources Extractive Industries Transparency Initiative (EITI): EITI is a coalition of gov- ernments, companies, civil society groups, investors, and international organizations that aims to strengthen governance by improving transparency and accountability of 66 Integrating Social Accountability Approaches into EI Projects the extractive sector. The Secretariat of the EITI is located in Norway, and its multi- donor trust fund is managed by the World Bank. Global Witness: Through field investigations and high-level advocacy, Global Wit- ness has worked to increase transparency in the flow of revenues from oil, gas, and mining companies to governments. It conceived and co-launched the Publish What You Pay campaign (description later in this list). Also, Global Witness is a leading participant in the EITI. International Council on Mining and Minerals (ICMM): Established in 2001, ICMM aims to improve sustainable development performance in the mining and metals industry. It brings together 22 mining and metals companies and 34 national and regional mining associations and global commodity associations. Natural Resource Charter: The Natural Resource Charter is a global initiative designed to help governments and societies effectively harness the opportunities created by natu- ral resources for national and community development. The Natural Resource Charter provides 12 precepts to inform and improve natural resource management. Natural Resource Governance Institute (NRGI): NRGI is a nonprofit policy insti- tute and grant-making organization that promotes the effectiveness, transparency, and accountability management of oil, gas, and mineral resources for the public good. It was formerly known as Revenue Watch Institute. Open Government Partnership (OGP): OGP brings together governments and CSOs at both the national and international levels. At the national level, govern- ments work with CSOs to develop and implement their OGP national action plans. Additionally, within OGP, the Independent Civil Society Engagement team works to broaden, strengthen, and engage a strong civil society network to participate in OGP, particularly at the national level. Oxfam America: OXFAM has a large and growing portfolio of work on transparency and accountability, including in extractive industries. It has a number of publications and project case studies on community engagement around EI projects. Oxford Centre for the Analysis of Resource Rich Economies (OxCarre): Estab- lished in October 2007, OxCarre is a global center of excellence in the economics of resource-rich countries. Publish What You Pay (PWYP): PWYP is a global network of civil society orga- nizations that are united in their call for oil, gas, and mining revenues to form the basis for development and improve the lives of citizens in resource-rich countries. It undertakes public campaigns and policy advocacy to achieve disclosure of informa- tion about EI revenues and contracts. Transparency and Accountability Initiative (T/A Initiative): The T/A Initiative is a donor collaboration that is working to expand the impact and scale of transparency and accountability interventions. Some of the publications from the T/A Initiative are available on the natural resource management website. I n t e g r a t i n g S o c i a l A c c o u n t a b i l i t y A p p r o a c h e s i n t o E I P r o j e c t s 67