We refer to your message of 19 October 2021 addressed to Dr Werner Hoyer, President of the European Investment Bank (EIB), inviting the EIB to respond to the allegations raised in a blog post by the advocacy NGO CEE Bankwatch Network regarding the activities of the Bank. The President has asked us to respond.

We would first like to thank you for giving the EIB the opportunity to comment on these allegations.

The EIB is the bank of the European Union (EU). As a public bank governed by EU Member States, the EIB finances sustainable projects in support of EU policy objectives and is committed to the highest possible level of transparency.

In addition to financing large projects directly, the EIB uses intermediated finance to support smaller projects and reach beneficiaries, such as SMEs, that would not otherwise be able to obtain EIB finance.

Intermediated finance inherently entails a division of responsibilities between the EIB and the financial intermediaries. In particular, the latter are generally responsible for sub-project identification, appraisal and monitoring, and for ensuring that all sub-projects financed with EIB funds remain in line with the applicable EIB policies and standards. Nevertheless, all sub-projects are submitted to the Bank, who retains the power to refuse them or assess them in detail.

Within this context, the EIB applies a risk-based approach to Environmental and Social (E&S) risks in intermediated operations. In addition to the core EIB excluded activities, activities that give rise to negative E&S impacts that are complex and cannot be adequately mitigated and/or remedied and/or compensated for (including but not limited to projects in protected areas, critical habitat, adversely impacting on indigenous Peoples) are contractually excluded from EIB’s intermediated finance.

Furthermore, within the EU, where around 90% of the EIB’s financing takes place, EU legislation requires competent authorities to ensure that the public concerned has the right to access information and participate in the decision-making on relevant projects with significant impacts on the environment.

Finally, the EIB publishes information on all of its intermediated loans in accordance with the EIB Group Transparency Policy (EIB-TP). In addition, all information or documentation held by the EIB (whether or not proactively published, relating to direct or intermediated finance, etc.) remain accessible upon request in line with the EIB-TP. In handling such requests, the EIB applies a presumption of disclosure, meaning that the requested information and documents will be disclosed subject to limited and well-defined exceptions to protect legitimate interests.

On the basis of the above, the EIB considers CEE Bankwatch Network’s allegation that “a third of EIB lending evades environmental and social rules” and the comparison of the EIB’s intermediated lending to “a black hole, with no information published” to be unsubstantiated. The opposite is true.

The EIB welcomes constructive feedback from civil society in order to improve its policies and practices. It has recently conducted a broad public consultation on its Transparency Policy, as well as on its revised Environmental and Social Sustainability Framework (ESSF). All of the feedback received from stakeholders is being reviewed and the EIB expects to put forward an improved Transparency Policy and ESSF in the coming weeks.