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
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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.
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