Washington D.C., March 14, 2024 - The IFC Board of Executive Directors approved IFC's Management Action Plan in response to an investigation of IFC's investment in Bridge International Academies conducted by the Compliance Advisor Ombudsman (CAO), IFC's independent accountability mechanism.
In 2013 and 2016, IFC invested a total of $13.5 million in equity to support expansion of Bridge, a company that ran a chain of for-profit private schools in Kenya and provided technical assistance to government schools in other African countries. The project was designed to support access to affordable, quality education for children from low-income backgrounds. IFC exited the equity investment in NewGlobe Schools, the parent company of Bridge, in March 2022.
CAO's investigation responds to allegations of child sexual abuse at Bridge schools in Kenya. CAO became aware of the allegations during a field visit to Kenya in February 2020 related to a separate investigation. CAO conducted an initial appraisal of the issues before initiating a compliance investigation in January 2021. The investigation focused on IFC's due diligence and supervision of Bridge with respect to its systems and their application to prevent and respond to instances of child sexual abuse.
CAO's investigation report found that IFC did not meet its environmental and social requirements under the Sustainability Policy and Performance Standards 1 and 4 on the Assessment and Management of Environmental and Social Risks and Impacts, and Community Health, Safety, and Security, respectively. Specifically, during IFC's environmental and social due diligence prior to investing in Bridge, CAO found that IFC did not consider the project's potential child sexual abuse risks or consider the capacity of its client to satisfy environmental and social requirements in relation to child sexual abuse risks and impacts. CAO also found that, during supervision, IFC did not sufficiently monitor or substantively address project-related child sexual abuse and gender-based violence (GBV) risks and impacts with its client, including prior to exiting the investment. CAO's report provides recommendations for IFC to contribute to remedying the project-related harm to survivors of child sexual abuse at Bridge schools and makes institutional recommendations to help IFC prevent and appropriately manage risks of child sexual abuse in future operations.
"Child sexual abuse is unacceptable in any project financed by the IFC," said IFC Managing Director Makhtar Diop. "Drawing lessons from this case, we are committed to improving our systems and ensuring a zero-tolerance culture for gender-based violence and child sexual abuse. We are recruiting additional GBV experts and are rolling out new training for IFC staff which includes clear reporting and escalation protocols. In Kenya, we will provide funding to support established remediation and prevention programs led by organizations with a solid track record of addressing child sexual abuse and gender-based violence. As part of our systemic improvements, we will also be adding specific provisions on child protection and GBV to IFC's Sustainability Framework when it is updated."
The Board-approved Management Action Plan was developed by IFC with input from Bridge and a number of civil society organizations and service-providers supporting women's and children's rights in Kenya. The action plan outlines several commitments and areas for improvement in response to CAO's recommendations, including:
- IFC will directly fund a remediation program for survivors of child sexual abuse in counties where Bridge operated or currently operates in Kenya. The funding will be for a minimum of 3 years and a maximum of 10 years, to be adjusted based on outcomes of the design phase.
- Financial support with the objective of enabling survivors of child sexual abuse to access the services covered in the program would be provided, on a case-by-case basis, as needed, after careful assessment.
- The modalities and eligibility for support will be determined in the design phase after consultation with stakeholders including local and international child protection experts, local and international non-governmental organizations active in survivors support and survivors of child sexual abuse that wish to come forward.
- Financial support could include cash payments for transportation, incidentals and lost wages resulting from accessing program services, and reimbursements for directly related past expenses that would otherwise have been eligible under the program, in accordance with the program procedures and subject to verification.
- The remediation program will be complemented by prevention activities aiming to engage local communities and services in counties in Kenya where Bridge operated or currently operates.
- Both the remediation and prevention programs will be informed by survivor-centered stakeholder engagement during design and implementation and the input of an advisory committee which will include relevant international and local GBV and child protection experts that are internal and external to the World Bank Group.
- IFC is undertaking a review of its portfolio to identify child sexual abuse and GBV risks and determine appropriate risk-management measures when needed. Progress on this review will be included in the first progress report on implementation of the Management Action Plan in a manner that complies with IFC's Access to Information Policy.
- IFC is reviewing the E&S provisions in template investment agreements and will develop covenants to be included where appropriate in relation to child protection and GBV prevention and notification by clients of related incidents.
- IFC is building its capacity—through hiring GBV experts, delivering staff training, and developing tools—to address and prevent GBV in projects. IFC will issue and operationalize a statement to staff on zero tolerance for inaction on, or reprisals for, addressing GBV or child protection issues.
Separately from the Management Action Plan, in response to other CAO recommendations, IFC has committed to strengthen child protection provisions when it updates the Sustainability Framework and to consider GBV and child protection in the implementation of its Responsible Exit Principles.
"CAO's report recommends meaningful remedial solutions for the harm experienced by survivors of child sexual abuse at Bridge schools in Kenya," said Janine Ferretti, CAO Director-General. "To achieve this objective, it is essential that inputs received from the survivors during IFC's consultation process inform the design of the remediation program. Its effective implementation will need to have Bridge students who experienced sexual abuse, and their families, at the center of the process. These are children who went to school to improve their lives and access the best education their families could afford. Sadly, for some of them, their lives were interrupted. This is a defining moment for IFC to make systemic improvements to embed child protection and GBV measures in its policies and processes, and train staff accordingly. We look forward to seeing these measures reflected when IFC updates its Sustainability Framework."
IFC management will supervise the implementation of the action plan and return to the Board for a meeting within six months to provide an update on progress and the final design of the remediation program based on consultation with stakeholders and, if needed, make adjustments. CAO will monitor effective implementation of the actions set out in the Management Action Plan and publish IFC's progress reports on its website and in an annual monitoring report.
More information about this case, including the CAO Investigation Report and IFC Management Action Plan, are available here:
Compliance Investigation Report
Management Response & Action Plan
About CAO
The Compliance Advisor Ombudsman (CAO) is the independent accountability mechanism of the International Finance Corporation (IFC) and the Multilateral Investment Guarantee Agency (MIGA), members of the World Bank Group. CAO's mandate is to address complaints from people affected by IFC and MIGA projects in a manner that is fair, objective, and constructive, improve environmental and social outcomes, and foster accountability and learning to reduce the risk of harm to people and the environment. For more information, visit www.cao-ombudsman.org.
About IFC
IFC — a member of the World Bank Group — is the largest global development institution focused on the private sector in emerging markets. We work in more than 100 countries, using our capital, expertise, and influence to create markets and opportunities in developing countries. In fiscal year 2023, IFC committed a record $43.7 billion to private companies and financial institutions in developing countries, leveraging the power of the private sector to end extreme poverty and boost shared prosperity as economies grapple with the impacts of global compounding crises. For more information, visit www.ifc.org.
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