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* Admissibility date reflects the date the case was officially registered. All other dates pertain to the date in which a stage was completed.
Case Description
End 2023 the European Investment Bank Group Complaints Mechanism (EIB-CM) issued an Initial Assessment Report (see link below) for the case SG/E/2023/04 regarding the resettlement process of the Project Affected People (PAP) that were operating an industrial activity impacted by the Zenata Urban Development Project. During the investigation of this complaint, the EIB-CM registered 12 complaints related to the resettlement process of informal businesses (PAPs that were operating small businesses in dedicated shops in the douars - also referred to as “Local à Usage Professional” or “LUP”). Those cases were registered under the case numbers SG/E/2024/17A to K and SG/E/2024/18.
Work performed
Since all these cases relate to economic displacement, the EIB-CM decided to handle them under one single compliance investigation. The EIB-CM performed a documentation review and held several meetings with the complainants and the promoter, including during a site visit in September 2024.
Conclusion
The conclusions report to these cases is available at the link below. In this report, the EIB-CM finds that the reinstallation of industrials, although lacking documentation, appears to have been generally satisfactory. For the informal businesses, the EIB-CM finds that the eligibility criteria defined in a project memorandum in 2015 are more restrictive than those defined in the RAP and are not in line with the EIB E&S Standard 6. The EIB-CM also found that the other informal business or subsistence activities (the ones that do not need a shop) were not considered in the RAP. It eventually appears that some compensation measures defined in the RAP were not implemented.
An external mid-term review of the implementation of the project’s Resettlement Action Plan (RAP), finalised in 2024 for the EIB, shares the same findings and recommends several measures to ensure the restoration of livelihoods of the economically displaced PAPs. The EIB-CM observed that these measures were added in the corrective action plan developed by the promoter and recently agreed upon with the Bank, following the recommendations in the CM’s two previous Conclusions reports SG/E/2021/08 and SG/E/2022/11(a), SG/E/2022/11(c), SG/E/2022/18. These measures include the development of a livelihood restoration plan (LRP) with the aim to support trainings, employment, and small businesses.
The EIB-CM found in general that there was a lack of adequate monitoring by the Bank of the RAP’s implementation concerning the resettlement of economic activities.
Outcome
Based on this assessment, and building up on the previous Zenata conclusions reports referred to above, the EIB-CM recommends that the EIB project team continues to work closely with the promoter to ensure that the LRP is finalized, properly budgeted, implemented as soon as possible and monitored closely.
The EIB-CM also suggests that the Bank works with the promoter to ensure the publication of the eligibility criteria established in April 2015 (more detailed eligibility criteria not reflected in the RAP), concerning industrial activities and informal commercial activities.
The EIB-CM eventually recommends that the Bank takes necessary measures in line with the financing contract (as amended by successive addenda) to ensure the finalization and effective implementation of the corrective action plan, which aims to bring the project into compliance with the EIB's E&S standards.
Monitoring
The EIB-CM is monitoring the development and implementation of its recommendations and suggestions to the EIB and of the corrective action plan agreed between the EIB and the promoter.