ENVIRONMENTAL AND SOCIAL RISK MANAGEMENT FOR IPFF II: QUALITY ASSURANCE

Transcription

1 Bangladesh Bank Investment Promotion and Financing Facility (IPFF) II Project Terms of Reference ENVIRONMENTAL AND SOCIAL RISK MANAGEMENT FOR IPFF II: 1. Background QUALITY ASSURANCE (Service package # IPFF II S3A) The Government of the People s Republic of Bangladesh (GoB) with support from the World Bank is undertaking the Investment Promotion and Financing Facility II (IPFF II) Project to help alleviate constraints in infrastructure financing. Development of infrastructure financing, which is by nature long term, is constrained in Bangladesh by the country s underdeveloped financial sector as well as the limited number of bankable infrastructure projects prepared/developed. IPFF II Project follows the successful implementation of IPFF, which was created in 2006 as a wholesale instrument providing liquidity required by primary lenders to extend long-term infrastructure loans. The core objective of IPFF II Project is to increase the provision for long-term financing and build capacity for infrastructure finance to promote sustainable private sector-led infrastructure development in Bangladesh. Broadly, IPFF II Project will achieve this through: (i) expansion of long term financing for infrastructure sectors in Bangladesh, including development of innovative financial products; (ii) contributions to scaling up private sector infrastructure development, including Public-Private Partnerships (PPPs); (iii) capacity building of government agencies, financial sector, project sponsors, and other stakeholders. More specifically, the two core components are as follows: Component 1: Long-Term Infrastructure Financing Component (US$ million). This component will provide long-term funds to PFIs for further onlending and investment in support of long-term infrastructure investments by private sector investors/companies. Component 2: Technical Assistance Component (US$13 million). This component will support infrastructure investment capacity building. Under component 1, Bangladesh Bank (BB) will be the main implementing agency, with funding provided to participating financial institutions (PFIs) that will, in turn, on-lend to infrastructure projects in the following key sectors. This list is indicative only and other infrastructure sectors may be financed as well. Page 1 of 18

2 1. Power generation, transmission, distribution, renewable energy, and services; 2. Port development (sea, river, and land) including inland container terminals, inland container depots, and other services; 3. Environmental, industrial, and solid waste management projects; 4. Highways and expressways including mass-transit, bridges, tunnels, flyovers, interchanges, city roads, bus terminals, commercial car parking, and so on; 5. Airports, terminals, and related aviation facilities; 6. Water supply and distribution, sewerage, and drainage; 7. Industrial estates & parks development, economic zone, eco park and theme park; 8. Information and Communication Technology (ICT), including WiMAX, internet backbone, and e-learning facilities; and 9. Social sector including health and education. Management of environmental and social (E&S) risks presents one of the most important challenges in infrastructure financing and the project has developed a comprehensive approach to this issue. 2. Project Implementation Arrangements Project implementation arrangement, key roles and responsibility of all stakeholders, and processes with regard to E&S risk assessment and management are summarized in the IPFF II E&S Policy and corresponding E&S Procedures document issued by IPFF II Project Cell, BB that may be updated from time to time. BB will be the main implementing agency for the project. BB s IPFF II Project Cell implemented the previous phase of the project, IPFF, and has gained substantial knowledge and skills on E&S risk management and other aspects of project management through project-based interaction with the PFIs. Compared to IPFF, the implementation arrangements for IPFF II will include revised and more structured E&S risk management approach through putting in place a formal Environmental and Social Management System (ESMS) at the levels of BB, PFIs, and project sponsors, as described below. As compared to IPFF, this system allocates the majority of key decision-making responsibilities to BB and PFIs in terms of managing E&S risk assessment process. 1 1 In IPFF, World Bank assumed core review and clearance function for E&S risk assessment and management instruments, while in IPFF II, this function will be assumed by IPFF II Project Cell, BB. Page 2 of 18

3 3. Overview of Environmental and Social Risk Management for IPFF II Project IPFF II Project is a complex project that involves a multilevel implementation structure. BB, PFIs, private sector project sponsors, other government agencies, specialized E&S agencies, and experts will play important and distinct roles. It is recognized that IPFF II subprojects are likely to be exposed to a variety of E&S risks that must be adequately managed so that IPFF II Project can be implemented in a sustainable manner. The approach to implementation of E&S risk management measures for IPFF II Project is that of putting in place and continually strengthening a formal ESMS. The ESMS will enable addressing E&S issues within the multilevel project structure, as well as capacity for implementing this system at all key levels - BB, PFIs, and private sponsor companies - to allow them to adequately identify, assess, and manage E&S risks and impacts of subprojects according to the requirements of the GoB and the World Bank Group. The ESMS for IPFF II Project consists of the following key components: (a) IPFF II E&S policies and procedures prepared and regularly updated by IPFF II Project Cell, BB (publicly disclosed); (b) adequate procedures at the PFIs level to help them fulfill their role in E&S risk management for the project with regard to environmental and social due diligence and monitoring for projects financed under IPFF II are prepared in line with applicable E&S requirements of GoB and World Bank, as specified below, and (c) systematic E&S risk management systems and processes at the project sponsor level, as required by the World Bank/ IFC Performance Standards. The infrastructure projects to be financed under IPFF II, as well as the IPFF II ESMS, will be designed and implemented in accordance with relevant requirements of the GoB and the World Bank. The applicable E&S requirements applied to this project include: (a) World Bank Performance Standards 2, and additionally, the approach for projects involving FIs 3 ; (b) a list of excluded activities, based in IFC Exclusion List, to the extent it can be logically applied to infrastructure sector investments 4 ; and (c) a List of E&S Sensitive Activities developed for the project based on the analysis 2 World Bank PS are, in effect, IFC Performance Standards on Environmental and Social Sustainability adopted as the World Bank PS in 2013 pursuant to World Bank OP IFC PS were first introduced in 2006 and updated in IFC PS can be found here: ance+standards/environmental+and+social+performance+standards+and+guidance+notes. 3 Commensurate with IPFF II multilevel project structure, BB is considered a wholesale FI, and PFIs are considered retail FIs. Consequently, OP/BP 4.03 requirements will be applicable to all FIs within the project structure. 4 IFC Exclusion List can be found here: t_exclusion_list. Page 3 of 18

4 of potentially high E&S risks and impacts in the areas of biodiversity, resettlement, tribal peoples and/or small ethnic communities 5, and cultural heritage. The latter is intended to limit investments in high risk infrastructure projects through PFIs with low E&S capacity. The use of World Bank / IFC Performance Standards model is relatively new for Bangladesh and will require a structured approach to enhancing capacity of BB, PFIs, and private project sponsors. These standards are rather different from the World Bank safeguard policies. World Bank/ IFC Performance Standards offer significantly more clarity and guidance in these circumstances than safeguards policies, thus enabling more comprehensive and uniform implementation across sub-projects. The positive outcomes expected from their application in the project are stronger, more integrated, yet more flexible approach to E&S risk management, wider and more comprehensive coverage of E&S issues based on more recent global best practice, as well as possibilities of coordination and parallel financing of infrastructure ventures between the World Bank and other multi-lateral and bi-lateral development partners, including IFC. Harmonization of standards, hence, is expected to result in better outcomes and streamlining of processes if coupled with a robust capacity strengthening approach for assessment and management of the E&S risks and impacts. 4. Process for Preparation and Clearance of Environmental and Social Risk Management Instruments Environmental and social due diligence (ESDD) is integrated into overall due diligence of IPFF II sub-projects under consideration, including the review of financial and reputational risks. IPFF II Project will only support those sub-projects that are expected to meet the applicable E&S requirements. ESDD for sub-projects is the primary responsibility of the project sponsors, with supervision from the PFIs, and further oversight by BB (IPFF II Project Cell). A summary of key roles and responsibilities of key IPFF II stakeholders for sub-project E&S due diligence are summarized in Table 1 below. A more detailed flowchart preparation and clearance of E&S risk assessment and management instruments is presented in Annex 1. 5 Term Indigenous Peoples in line with Page 4 of 18

5 Table 1. Key IPFF II Stakeholders and Their Roles and Responsibilities for E&S Initial Screening, Due Diligence, and Supervision Core Functions Initial E&S screening E&S assessment (identificatio n of E&S risks and impacts) E&S risk rating of subprojects Subproject supervision/ performance monitoring Project Sponsors 6 PFIs BB World Bank Conduct initial E&S screening and prepare screening report Prepare ESIA and/or audit, as needed; comply with ESAP Develop E&S instruments in accordance with subproject E&S risk rating Implement monitoring actions at subproject level Work with project sponsors to ensure E&S screening is done against a defined set of IPFF II E&S eligibility criteria for sub-projects. Ensure E&S assessment and management instruments are prepared and cleared; legal covenants (including ESAP) in agreements with project sponsors Assign sub-project E&S risk rating (initial at screening stage and final at assessment stage) Monitor sponsor s compliance with agreed measures Review and validate E&S screening report; make decision on subproject selection Review and provide clearance for E&S instruments (ESIA, ESMP, ESAP, and other plans, as relevant) Clearance of E&S risk rating proposed by the PFIs Oversee monitoring process; engage external expertise Provide concurrence on subproject eligibility only (with regard to the E&S aspect) Provide no objection on E&S instruments in defined high risk situations as per IPFF II E&S Policy. Observe the process as part of supervision activities Conduct supervision / implementation support activities 6 Where project sponsors are not yet involved at the time of initial E&S screening, these responsibilities will be assumed by the agency or stakeholder responsible for sub-project design and preparation as per section of this IPFF II E&S Policy. Page 5 of 18

6 5. E&S Technical Committee for IPFF II Project Notably, to perform its clearance function for E&S risk assessment and management instruments for projects, BB will establish an E&S Technical Committee in order to ensure appropriate technical compliance of IPFF II supported sub-projects with applicable E&S requirements stipulated in IPFF II E&S Policy. The IPFF II E&S Technical Committee will perform the following key functions: 1. Review a summary of relevant E&S assessment documentation for sub-projects considered for IPFF II financing, as presented by BB s IPFF II Project Cell; this may include providing feedback on the documentation to PFIs, projects sponsors, and other relevant agencies that may have prepared such documentation; 2. Provide formal clearance or validation of (i) ESIA package for each sub-project, including ESAP, ESMP, and other thematic management plans prepared in accordance with the applicable E&S requirements for IPFF II sub-projects and (ii) final E&S risk rating for sub-projects; 3. Recommend sub-project approval for financing on E&S grounds to the overall IPFF II approval committee/ function; 4. Advise on the actions needed to improve quality of the E&S documentation for sub-projects, IPFF II E&S procedures and processes for managing E&S risks in sub-projects considered for financing. 6. Scope of Services The consultant will be required to work under close supervision of IPFF II Project Cell, BB and provide support to IPFF II Project Cell, PFIs, relevant market participants and relevant government authorities to undertake the following tasks: A. QUALITY ASSURANCE to support PIU for preparation and quality assurance of E&S risk assessment and management instruments: o Support to the IPFF II Project Cell, PFIs, and project sponsors with the initial E&S screening and scoping of projects proposed for IPFF II financing, and validation of the initial E&S risk ratings, as proposed by PFIs; o Where project sponsors and/or PFIs are not yet identified at the screening stage, assist relevant agencies that may be conducting initial E&S screening and scoping of proposed projects; o Prepare a set of sample sub-sector TORs for the nine sub-sectors identified in section 1 above for the IPFF II Project Cell and PFI use, as well as detailed and specific TORs for environmental and social impacts assessments for each proposed project; these ToRs will be made available by IPFF II Project Cell to PFIs and project Page 6 of 18

7 sponsors to facilitate commissioning of E&S risk assessment studies and preparation of E&S management plans for infrastructure projects proposed for IPFF II financing; o Conduct initial review of the E&S assessment studies and management plans submitted for review to IPFF II Project Cell by project sponsors through PFIs and provide qualified technical opinion to IPFF II Project Cell on the completeness and adequacy of the instruments, in line with World Bank/ IFC Performance Standards; in necessary, provide up to two rounds of detailed comments on the instruments and return them to PFIs for improvement; o Visit IPFF financed sub-projects as well as sub-projects awaiting financing from IPFF II Project as and when required in order to monitor E&S compliance.assist IPFF II Project Cell in ensuring that all required clearances are obtained by project sponsors according to GoB requirements; o Advise IPFF II E&S Technical Committee on the adequacy of the project categorization proposed by PFIs; o Review detailed ToRs for E&S risks and impact assessment (prepared by project sponsors) for specific projects proposed for IPFF II financing and assist PFIs and project sponsors in identifying qualified technical expertise to conduct E&S assessments (both local and international); o Support PFI/project sponsors and/or their consultants for conducting consultation and disclosure of ESIA, ESMPs, RAPs, LRPs, BMPs etc. as per IPFF II E&S Policy and corresponding E&S Procedures adopted by BB; o Evaluate quality of final ESIAs, ESMPs, project sponsor ESMS, ESAPs, and other instruments and recommend clearance to the IPFF II E&S Technical Committee; o Assist in ensuring that appropriate E&S legal covenants are included in financing agreements between PFIs and project sponsors, including the agreed time-bound ESAPs; o Prepare annual environmental and social performance report ( ESPR ) that summarizes the status of implementation of the IPFF II ESMS throughout construction and implementation of the subprojects. o Conduct Performance rating of PFIs on a yearly basis or at the time of the PFI s request for financing under IPFF II, whichever is sooner. o Prepare a summary of key provisions of the ESPP for communication purposes. Page 7 of 18

8 B. TECHNICAL CAPACITY BUILDING will focus on evaluating and taking concrete steps to increase available E&S technical capacity in Bangladesh: o Conduct a rapid assessment study of the current level of technical capacity in Bangladesh for undertaking E&S assessment against international standards, and more specifically, World Bank/ IFC Performance Standards; the study must include a survey of E&S firms providing such services in Bangladesh and will determine (a) overall availability of expertise; (b) key capacity and knowledge gaps; and (c) a more detailed training needs assessment and training plan, including specific training interventions, timeline and budget. o Prepare and conduct an E&S training program, based on the plan identified in the study. This training program must be approved by BB and shall include: (a) developing a 2 3 year training plan (with an intensive phase in year 1 and ongoing training in years 2 and 3); (b) preparation of training materials; and (c) of training. It should be assessed whether there is scope for a for-fee training program that will require a percentage contribution from the firms/experts, to be more selfsustained. PFIs and project sponsors should be also engaged and encouraged to take part in training to strengthen their internal knowledge and technical capacity; 7. Deliverables, Payment Schedule, and Duration The consultancy will be based on a contract that will be divided into remuneration packages as presented in Table 3. Remuneration packages will be divided into: (i) lump sum contract divided into % on of certain outputs that are overarching and are not clearly linked to individual infrastructure projects to be financed under IPFF II; (ii) fixed amount payments on of certain outputs that are clearly linked to individual infrastructure projects to be financed under IPFF II. The initial period of consultancy will be one year, with possible extension based on the quality of services provided. Lump sum and fixed amounts to be quoted by the firms as part of their financial proposals). Level of effort for activities clearly linked to individual infrastructure projects to be financed under IPFF II should be proposed per project. Page 8 of 18

9 Table 3. Deliverables, Timelines, and Payment Schedule Sl. no. Name of deliverables Frequency/Time line Remuner ation package Payment (% or fixed amount) A. QUALITY ASSURANCE to support PIU for preparation and quality assurance of E&S risk assessment and management instruments: 1. Work plan and inception report 2. A set of nine sample TORs for E&S risks and impact assessment (per the list of subsectors listed in section 1 above) 3. Support to project sponsors and PFIs in initial E&S screening and scoping of projects proposed for IPFF II financing (completed detailed E&S screening and initial categorization form as per IPFF II E&S Procedures) One time [First month (Second week after contract becomes effective)] One month after contract becomes effective As needed in line with IPFF II project timelines and sub-project pipeline Fixed lump sum Fixed lump sum Payment on One-time payment, equal to 10% of the total lump sum value of remuneration excluding fixed payments on One-time payment, equal to 15% of the total lump sum value of remuneration excluding fixed payments on Fixed amount per project/ screening completed and approved by IPFF II Project Cell, BB 4. Review of the detailed TORs for E&S risks and impact assessment for specific projects proposed for IPFF II financing (prepared by project sponsors) and identification of options for engaging qualified expertise to As needed in line with IPFF II project timelines and sub-project pipeline Payment on Fixed amount per TOR Page 9 of 18

10 carry out the assessments (up to two rounds of comments) 5. Review of ESIA, ESMS, ESMP, ESAPs and associated instruments completeness and quality, risk category, and recommendations to IPFF II E&S Technical Committee specific projects proposed for IPFF II financing (up to two rounds of comments) As needed in line with IPFF II project timelines and sub-project pipeline Payment on Fixed amount per project E&S package reviewed 6. Annual E&S performance reports First report one year after IPFF II project effectiveness Payment on Fixed amount per report 7. Performance rating of PFIs 8. Preparation of a list of qualified local and international consultants to conduct E&S assessments for eligible sectors of IPFF II 9. Prepare a summary of key provisions of the ESPP for communication purposes On a yearly basis or at the time of the PFI s request for financing under IPFF II, whichever is sooner Three months after contract becomes effective Two months after contract becomes effective. Payment on Fixed lump sum Fixed lump sum Fixed amount per report One-time payment, equal to 5% of the total lump sum value of remuneration excluding fixed payments on One-time payment, equal to 10% of the total lump sum value of remuneration excluding fixed payments on Page 10 of 18

11 B. TECHNICAL CAPACITY BUILDING for evaluating and taking concrete steps to increase available E&S technical capacity in Bangladesh: 1. E&S technical capacity assessment study and training needs assessment (inducing a roster of E&S technical firms in Bangladesh) 2. E&S training program design 3. E&S training program Two month after contract becomes effective Three month after contract becomes effective Initial set of trainings within six months after contract becomes effective and regular follow-up trainings thereafter Fixed lump sum Fixed lump sum Fixed lump sum One-time payment, equal to 15% of the total lump sum value of remuneration excluding fixed payments on One-time payment, equal to 10% of the total lump sum value of remuneration excluding fixed payments on Periodic payment as follows: (i) payment after completion of initial set of trainings, equal to 25% of the total lump sum value of remuneration excluding fixed payments on (ii) payment after completion of one year of consultancy (provided followup trainings were delivered), equal to 10% of the total lump sum value of remuneration excluding fixed payments on Page 11 of 18

12 8. Required Skills and Qualifications Skills and qualification of the consulting team are summarized in Annex Reporting Obligation and Oversight The consultant will work independently and will report to IPFF II Project Cell of BB and maintain a close coordination with the entire IPFF team of BB. Page 12 of 18

13 Annex 1. IPFF II Environmental and Social Due Diligence and Supervision Process for Projects Financed Subproject proposal submission to IPFF Project Cell, BB (PFI) Task 1: Initial E&S Screening of subproject (Project sponsor or other agency, in coordination with PFI and with support from IPFF II quality assurance implementation partner for E&S risk assessment and management process and instruments) Task 2: Private sponsor E&S screening (once involved) Bangladesh Bank Task 3: PFI E&S performan ce rating (once involved) Bangladesh Bank PFI E&S capacity building activities (with support of the FI capacity building implementation partner(s)) Initial E&S screening report review in conjunction with PFI E&S performance rating and private sponsor eligibility criteria (IPFF Project Cell, BB) IPFF II E&S Eligibility Criteria met Preparation of ESIA, ESMP, ESAP (project sponsor or other agency, in coordination with PFI, where involved). TORs to be reviewed by BB and cleared by PFI (for High risk sub-projects) Feedback and revisions Final Subproject E&S Risk Rating (High or Medium*) per BB ESRM Guidelines IPFF II E&S Eligibility Criteria not met Subproject rejected Disclosure, consultation, stakeholder engagement (project sponsor/ other agency/ government/ PFI/BB) DoE clearance and obtaining ECC High Risk Rating (Subproject) Medium Risk Rating (Subproject) Review and clearance of subproject E&S instruments and ESAP (IPFF II E&S Technical Committee) No objection from World Bank in high risk situations defined in IPFF II E&S Policy Final recommendation from IPFF II E&S Technical Committee Sub-project approval by BB is communicated to the PFI and project sponsor Subproject implementation (monitoring by project sponsors, PFIs, BB with assistance of E&S performance monitoring implementation partner) * Note: Low risk rating for IPFF II sub-projects is not allowed per IPFF II E&S Policy PFI includes E&S conditions in subproject documentation with private sponsor (including ESAP) Annual renewal of ECC (project sponsors) Implementation support, incl. post-review (WB) Page 13 of 18

14 Annex 2. Qualifications, Experience and Responsibilities of Consultants Note: CVs of experts shall be provided as part of technical proposals. Any replacement of these experts on the team without proper justification acceptable to BB will result in cancellation of the contract by BB. New / replacement experts must have same or higher level of required qualification and be acceptable to BB. Role Qualifications Experiences Responsibilities Team Min. Masters degree in Environmental Should have previously worked leader (1) Management/ Geography/Geology/Urban as team leader in conducting Development/Civil Engineering etc. from a ESIAs for large projects. reputable university/institution. Minimum relevant experience will be 15 years Must have in depth knowledge and understanding of E&S issues and their management in infrastructure projects Must have working knowledge of Bangladeshi E&S legislation framework and EIA requirements Must have knowledge of best international practices and standards for E&S assessment and management; in-depth knowledge of World Bank/ IFC Performance Standards 7 is required. This must include World Bank Group Environmental, Health, and Safety Guidelines. Good communication skills (oral and written) in English Working experience with preparing ESIA instruments for projects financed by IFC and/ or Equator Banks is required Demonstrated interpersonal skills and proven ability to work in a different multicultural context Have demonstrated capacity to work independently and produce quality report on environmental assessment and audit; and produce comprehensive review reports on other relevant documents Team leader will be overall-in-charge of leading the team, review the quality of deliverables and assign task to the team members. He/ she will ensure timely of the assignment and coordinate with the team members 7 Page 14 of 18

15 Environme ntal Specialist (1) Min. Masters degree in Environmental Management / Civil Engineering/ Urban Development etc. or an equivalent professional degree from reputable universities/institutions. Must have skills preparation of ESIAs, ESMPs, and other related instruments for medium and large infrastructure projects across several sectors Good communication skills (oral and written) in English At least 10 years of practical experience in ESIA instruments preparation under World Bank/IFC Performance Standards Working experience in preparation of ESIA instruments across core environmental disciplines (pollution incl. GHG emissions, biodiversity, OHS) is strongly preferred Working experience with preparing ESIA instruments for projects financed by international financial institutions or Equator Banks with strong E&S standards Lead quality assurance and other related tasks with regard to environmental aspects of IPFF II Page 15 of 18

16 Social Specialist (1) Min. Masters degree in Social Sciences / Anthropology etc. from a reputable university/institution. Must have skills in preparation of ESIAs (social aspects), ESMPs, Resettlements Plans and other related instruments for medium and large infrastructure projects across several sectors Good communication skills (oral and written) in English At least 10 years of practical experience in ESIA instruments preparation under World Bank/IFC Performance Standards (more specifically, resettlement plans, stakeholder engagement plans, tribal people s plans etc). Working experience with regard to labor and working condition and community health and safety aspects of ESIAs Lead quality assurance and other related tasks with regard to social aspects of IPFF II Working experience with preparing ESIA instruments for projects financed by international financial institutions or Equator Banks with strong E&S standards Page 16 of 18

17 Capacity building expert (1) Min. Masters degree in Environmental Management/ Civil Engineering / Economics or other relevant discipline from a reputable university/institution. Must have track record of preparing training materials for relevant audiences and of training Lead capacity assessment and training tasks Must have knowledge of best international practices of E&S risk management in global project finance (multilateral institutions, Equator Banks); familiarity with World Bank/ IFC Performance Standards is required Must have track record in sector capacity assessment Minimum relevant experience will be 10 years Good communication skills (oral and written) in English Sector Specialists (appr. 6 correspondi ng to 9 priority industries identified for IPFF II financing) Must have advanced degree in Engineering/Physical/Environmental sciences, with background in specific industries to be covered by IPFF II financing. Knowledge and application experience of WG/IFC Performance Standards, including WBG Environmental, Health, and Safety Guidelines in the specific industry sectors Good verbal and written communication skills in English About 10 years of experience in environmental and social issues related to construction, operation, health and safety in an industry to be covered by IPFF II Sector experts should be available on call basis to provide inputs into the quality and completeness review of E&S risk assessment and management instruments for IPFF II-financed infrastructure projects Page 17 of 18

18 Annex 3. The World Bank / IFC Performance Standards (PS) 8 PS1: Assessment and Management of Environmental and Social Risks PS2: Labor and Working Conditions PS3: Resource Efficiency and Pollution Prevention PS4: Community Health, Safety and Security PS5: Land Acquisition and Involuntary Resettlement PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources PS 7: Indigenous Peoples PS8: Cultural Heritage *IFC Guidance Notes 8 accompanying the IFC PS are not included in the Bank PS. However, IFC Guidance Notes may be consulted for good practice guidance. 8 Standards/Performance-Standards Page 18 of 18