Asia Society Policy Institute

For Overseas Projects:

The State-owned Assets Supervision and Administration Commission of the State Council (SASAC) should:¹

• Publish a negative list of overseas investment projects of central state-owned enterprises (CSOEs). Determine which projects are prohibited or require special supervision.
• Randomly supervise and inspect the decision-making, implementation, and impacts of major projects.
• Work with CSOEs to establish an investment information system covering monitoring, analysis, and management of projects and their risks in real time.

Developers and Contractors that are CSOEs should:²

• Report to SASAC for an investor review of overseas investment projects listed in the special supervision category of the negative list. Submit a report on each investment, as well as a report on risk prevention and control.

The Chinese Government should:

• Encourage scientific evaluation and social supervision of the performance of Financiers, Developers, and Contractors.³
• Work with Developers and Contractors to improve the system for registering and reporting on overseas investments, strengthen the monitoring and analysis of green development, and enhance information-based supervision.⁴

Financiers should:

• Set the following minimum reporting requirements for Developers and Contractors:⁵
  • Category A Developers and Contractors should evaluate and report on their environmental and social assessment and management (ESAM) plan every six months. See Project Categorization and Screening for information about the China Banking and Insurance Regulatory Commission’s (CBIRC) recommended categories and related requirements.
  • Category B Developers and Contractors should evaluate and report on their ESAM plan once a year.
• Conduct audits or assessments to monitor environmental and social risks throughout the project life cycle.⁶
  • Develop procedures to monitor and report on climate-related risks.⁷
  • As part of post-loan management, supervise the implementation and operation of projects.⁸
  • Conduct on-site — potentially independent — investigations in accordance with environmental and social impact assessment (ESIA) results.⁹
    • For Category A Developers and Contractors, conduct an on-site examination of Developers’ and Contractors’ systems for managing environmental and social risks, as well as the implementation of the risk response scheme. Consider inviting qualified, independent Experts or other third parties for the examination.
  • Focus on Developers’ and Contractors’ performance in energy saving and emissions reduction, environmental protection, clean production, work safety, and social management.¹⁰
  • Suspend or withdraw funding if there are major risks or dangers.¹¹

Developers and Contractors should:

• Establish and maintain a comprehensive monitoring and evaluation system as part of the Preparation and Implementation of Environmental and Social Management Plan (ESMP).¹²
  • Set targets for continuous improvement.¹³
• Monitor the effectiveness of community engagement activities throughout the project life cycle.¹⁴
  • Draw on lessons learned from monitoring results to improve community engagement.
• Set up a health monitoring system at each project site.¹⁵
• Regularly assess social and environmental impacts during the project implementation and operations phases.¹⁶
  • Monitor compliance with host country requirements in a timely and effective manner.¹⁷
  • Track their carbon footprint.¹⁸
• Monitor their own performance on carrying out the ESMP.¹⁹
  • Track social responsibility performance.²⁰
  • Track activities to protect the environment; ecosystems; precious, rare, threatened, or endangered species and their habitats; and efforts to rehabilitate disturbed areas.²¹
  • Use a combination of qualitative and quantitative indicators to track the effectiveness of mitigation measures.²²
  • Regularly maintain records of the scope and intensity of project activities.²³
  • Incorporate results from routine assessments into environmental and social management systems (ESMSs).
• Communicate with host countries' environmental protection monitoring agencies and seek out their advice.²⁴
• Monitor the effectiveness of each project’s health and safety (H&S) programs.²⁵
• Publicly disclose monitoring results.²⁶
  • Report on each project’s progress to companies’ senior management.²⁷
  • Share monitoring reports with Financiers in accordance with requirements for frequency set during the pre-project planning phase.
  • Report on their progress to Affected People through personal communication, online dialogue, direct consultation with these stakeholders, online reporting, and public disclosure of annual reports.²⁸
  • Produce an official report with information about how adverse impacts are being addressed.²⁹
  • Regularly issue accountability reports, sustainability or sustainable development reports, social responsibility reports, and financial reports.³⁰
• Take into account internal and external feedback on monitoring results, including feedback from Affected People.³¹
  • Set up an evaluation form for Affected People to provide feedback and share their observations during project implementation and operations phases.³²

For Domestic Projects in China Only:

Developers and Contractors should:³³

• Include a monitoring proposal in each environmental impact assessment (EIA) report.

The Chinese Government should:

• Establish and improve rules for environmental and health monitoring.³⁴
• Authorize Local Environmental Protection Departments to conduct an on-site inspection of Developers and Contractors that discharge pollutants.³⁵
• Disclose information about the supervision and inspection of environmental protection and public health.³⁶
  • Publicly disclose results from environmental performance evaluations.³⁷

Environmental Protection Departments should:

• Establish and design an environmental monitoring system and network.³⁸
  • Develop monitoring norms and create a network to monitor environmental quality and share data.³⁹
  • Investigate the environmental situation within their jurisdiction.⁴⁰
• Inspect, monitor, and record information about the implementation of environmental protection measures.⁴¹
  • Conduct on-site inspections of polluting infrastructure.⁴²
  • Proactively disclose inspection and approval results of environmental protection projects.⁴³
• Release environmental quality information to the public. Promote the disclosure of air and water quality information.⁴⁴
• Publish the list of illegal polluting Developers and Contractors.⁴⁵
• Publish the "List of National Key Monitoring Enterprises."⁴⁶

During the pre-project planning phase, Financiers, Developers, and Contractors should:

• Establish appropriate procedures for reviewing and acting on monitoring reports.
  • Disclose information about these procedures on their own websites.

Developers and Contractors should:

• Allocate adequate funds in the project budget toward monitoring and reporting.
• Ensure that the ESMP includes the following information about project monitoring and reporting:
  • Monitoring objectives.
  • The specific type of monitoring scaled to the impacts, risks, and mitigation measures outlined in the ESIA report and ESMP.
  • An explanation of the technical details of monitoring measures, including the methods, parameters, sampling locations, frequency of measurements, thresholds for corrective actions, and detection limits.
  • Procedures for measuring project progress and results of mitigation.
  • Institutional arrangements and responsibilities for each type of monitoring.
  • Procedures that allow for early detection of conditions that require corrective actions through an environmental and social action plan (ESAP).
• Determine performance indicators to track stakeholder engagement, as well as environmental and social performance. See Preparation and Implementation of Environmental and Social Management Plan (ESMP) for more information about how this planning process works.
  • Consider adopting multilateral development banks’ (MDBs) environmental and social safeguards and/or developing a set of measurable outcomes and targets based on international best practice to monitor project outcomes.

Financiers should:

• Include the following requirements for Developers and Contractors in their project financing agreements:
  • Hire independent Experts to monitor projects or verify monitoring information.
  • Provide independent monitoring mechanisms to collect feedback and additional data from Affected People, CSOs/NGOs, and other stakeholders.
  • Submit periodic monitoring reports on their performance in environmental and social management within certain time frames during the project implementation and operations phases. The following time frames are recommended:
    • At least on a quarterly basis during the project implementation phase for highly complex and sensitive projects.
    • At least on a semiannual basis during the project implementation phase for projects with significant adverse impacts on the environment, impacts leading to involuntary resettlement, or impacts on Indigenous peoples.
    • At least on an annual basis during the project operations phase for projects with significant adverse impacts.

During the project implementation and operations phases, Developers and Contractors should:

• Establish a database or news hub on their own websites to disclose information about ongoing monitoring activities and results.  
• Hire and train an adequate number of personnel to manage project monitoring and reporting.
  • Assign responsibilities to project workers based on their experience and training.
• Hire qualified and experienced Experts — either individually or as part of an advisory panel — to monitor each project.
  • Request approval of these Experts from Financiers.
  • Ensure these Experts are independent from Financiers, Developers, Contractors, and other project proponents, especially for higher-risk projects.
  • If host country laws and regulations require national or subnational agencies from the Host Country Government to be involved in project monitoring, hire qualified and experienced Experts to regularly verify the monitoring information.
• Cover costs associated with the participation of Affected People, CSOs/NGOs, and other key stakeholders in environmental and social monitoring.
• Facilitate site visits for Financiers or independent Experts representing Financiers.

Financiers should:

• Approve or reject Experts proposed by Developers and Contractors. These Experts should either independently monitor each project or, at minimum, verify monitoring information collected by Developers, Contractors, and/or Relevant Agencies of the Host Country Government.
• Conduct periodic site visits to review mitigation and monitoring measures for projects.
• Send selected Experts to project sites to supervise projects with significant adverse social or environmental impacts

Designated Experts, Staff, and/or Relevant Agencies of the Host Country Government should:

• Undertake regular environmental and social monitoring within the project area of influence.
  • Conduct periodic inspections, audits, and assessments to evaluate environmental and social impacts, as well as the delivery of community benefits. 
    • Include H&S risks to workers and local communities, as well as working conditions and hours of work.
    • Quantify and monitor biodiversity impacts and greenhouse gas (GHG) emissions annually in accordance with internationally recognized methodologies (e.g., Intergovernmental Panel on Climate Change (IPCC)).⁴⁷
  • Survey households of Affected People to better understand issues caused by each project and changes in local living standards and livelihoods.
    • Disaggregate data by gender and community to ensure that the needs and expectations of the most vulnerable individuals and groups are being monitored.
    • Continue to monitor resettlement and livelihood outcomes until a monitoring report concludes that Affected People have received all of the compensation and assistance for which they are eligible, as well as adequate opportunities to restore their livelihoods.
  • Document monitoring results for submission to Developers and Contractors.
• Establish an independent monitoring mechanism for Affected People, CSOs/NGOs, and other key stakeholders to provide feedback on monitoring activities and results for each project.
  • Ensure that this mechanism is culturally appropriate and gender-sensitive.
  • Inform key stakeholders of the differences in functions — and independence — between the project-level grievance mechanism and the independent monitoring mechanism.
  • Respond to stakeholder feedback and provide information about corresponding actions to be taken.
• Engage Affected People, CSOs/NGOs, and other key stakeholders in routine processes for sharing and validating data as part of project monitoring.
  • Work with a diverse group of community representatives — not solely Community Leaders — and CSOs/NGOs to organize a collaborative monitoring council for each project. For larger and/or higher-risk projects, consider organizing a more formalized community coordination committee with representation of Developers, Contractors, Subcontractors, Affected People, CSOs/NGOs, and other key stakeholders.
  • Allow Affected People to choose their representatives for the collaborative monitoring council or the community coordination committee.
    • Ensure that the perspectives, interests, and needs of vulnerable groups are represented by at least one community member (e.g., a woman; a person of every ethnic, religious, or linguistic minority; a member of an Indigenous community; an elderly person; a young person; and a person with a disability).
  • Provide support and training in evaluation, monitoring, and reporting to community representatives and CSOs/NGOs that are participating in the collaborative monitoring council or the community coordination committee.
  • Ensure that all participants have been informed of the contents of the ESIA report, ESMP, conditions of approval, project contracts/agreements, and other relevant documentation and that they can readily access and review these materials.
  • Convene each collaborative monitoring council or community coordination committee on a monthly basis to discuss the project. For larger projects that span multiple communities, inform each council/committee of takeaways from meetings with other communities’ councils/committees.
    • Record meeting minutes and summaries. Provide copies of these materials directly to participants, Developers, Contractors, Subcontractors, and where applicable the Host Country Government.  
    • Maintain a record of attendees.
  • Follow up on stakeholders’ comments/queries/concerns/complaints with appropriate responses and corresponding actions at future meetings.
• Prepare project-specific monitoring reports with technical data and information covering the following components:
  • Scope of mitigation, evaluation, and monitoring activities.
  • Results from monitoring activities related to environmental and social impacts, including but not limited to resettlement and livelihood restoration, Indigenous peoples, cultural heritage, and natural resource management (NRM).
  • Levels of toxic waste, pollutants, and other emissions in comparison with host country, Chinese, and/or international standards.
  • Information about meetings with Affected People, CSOs/NGOs, and other key stakeholders.
  • Community concerns, as well as corresponding responses and actions.
  • Compliance (and noncompliance) with project conditions and other commitments attached to the approval of funding and the overall project, as well as corresponding remedial, compliance, and enforcement measures.
  • Necessary corrective actions to be detailed in an ESAP.
  • Updates to the ESMP.
  • Project spending on mitigation measures, monitoring systems, project commitments, community benefits, community development funds, and compensation as percentages of overall project spending.
  • Project status.
• Submit these monitoring reports to Developers, Contractors, and Subcontractors for review.

Developers and Contractors should:

• Submit periodic environmental and social monitoring reports to Financiers and the Host Country Government per the time frames set in project agreements and contracts.
  • For higher-risk projects, submit supplementary reports on involuntary resettlement, livelihood restoration, Indigenous peoples, cultural resources, and NRM.
• Regularly disclose meeting minutes and summaries from monthly meetings of the collaborative monitoring council or the community coordination committee, as well as project-specific monitoring reports, on their websites.
  • Keep physical copies of monitoring reports at Developers’ headquarters and local office(s), where applicable.
• Prepare and publicly disclose company-wide reports summarizing the following information for each project on an annual basis, at minimum:
  • Evaluation and monitoring activities.
  • Monitoring results.
  • Project finances.
  • Compliance and enforcement activities through the ESAP.
• Share monitoring results and relevant information with Affected People, CSOs/NGOs, and other stakeholders in a timely manner.

The Host Country Government should:

• Regularly disclose meeting minutes and summaries from monthly meetings of the collaborative monitoring council or the community coordination committee, as well as project-specific monitoring reports, on their websites and at the village/town/city/district/provincial hall.
  • Keep physical copies of monitoring reports at national and subnational government office(s) dedicated to environmental and social issues.
• Formally review and approve environmental and social monitoring reports to ensure projects continue to align with host country laws and regulations.
• Share monitoring results and relevant information with Affected People, CSOs/NGOs, and other stakeholders upon request in a timely manner.

Financiers should:

• Formally review and approve environmental and social monitoring reports.
  • Evaluate Developers’ compliance with mitigation and monitoring measures set out in the ESMP and project financing agreements.
  • Track Developers’ and Contractors’ progress toward desired outcomes for project implementation and operations.
• Disclose project-specific monitoring reports on their websites upon receipt.
• Prepare and publicly disclose annual reports on institution-wide performance based on individual projects’ environmental and social monitoring reports.
• Provide implementation support, as needed, to Developers and Contractors to ensure that mitigation and monitoring activities set out in project agreements have been carried out properly within the agreed upon time frames.
• Prepare a project completion report once the project implementation phase ends.
  • Evaluate whether desired environmental and social outcomes have been achieved.
  • Compare monitoring results with baseline conditions outlined in the ESIA report, ESMP, land acquisition and resettlement plan (LARP), livelihood restoration plan (LRP), Indigenous peoples plan (IPP), and other documents.
  • Include lessons learned for similar projects in the future.
  • Include a copy of each environmental and social monitoring report provided by Developers and Contractors in the appendices.
• Disclose the project completion report on their websites.⁴⁸

• During the pre-project planning phase, browse the websites of Financiers, Developers, Contractors, and the Host Country Government for information about their policies, procedures, and/or mechanisms for monitoring and reporting.
  • If any of this information is unavailable, ask the appropriate actor to publicly disclose specific details in your native language. See Stakeholders to identify some of the available mode(s) of contact.
  • If you are unable to directly contact the Developers and Contractors, reach out to Financiers and/or the Host Country Government for assistance.
  • If you are unable to directly contact the Financiers and/or the Host Country Government, reach out to a Community Leader or CSO/NGO for assistance.
• During the project implementation and operations phases, ensure that you are aware of the contents of the ESIA report, ESMP, conditions of approval, project contracts/agreements, and other relevant documentation and that you can readily access these materials for a cross-comparison with monitoring reports.
• Join the collaborative monitoring council/community coordination committee or nominate a trusted member of your household or community to participate.
  • Speak with Developers, Contractors, and/or Experts about any support and training on evaluation, monitoring, and reporting that you may need.
• Attend project meetings related to environmental and social monitoring.
  • Speak with Experts and community representatives on the collaborative monitoring council or the community coordination committee about your needs, as well as land/houses/structures/assets/services that belong to you, your family, or your community.
  • Ask about future meetings.
  • Ask Financiers, Developers, Contractors, and the Host Country Government to reimburse transportation costs and cover other costs associated with attendance.
  • Maintain a record of your attendance and participation — on either paper or your phone.
  • Ask Experts, Developers, and/or Contractors to provide physical and/or digital copies of monitoring reports in your native language. Review these materials.
  • Discuss the project’s past, present, and future risks and impacts, as well as potential corrective and preventive actions, with other community members, CSOs/NGOs, and appropriate Experts both during and after each meeting.
  • Provide feedback directly or anonymously through the independent monitoring mechanism. Consider providing feedback directly to Experts, Developers, Contractors, and the Host Country Government.
• If you have not heard about the project’s monitoring meetings, browse the websites of Developers, Contractors, and the Host Country Government for information about when and where future meetings will be held, as well as who the facilitators are and how they can be contacted.
  • If any of this information is unavailable, ask Developers, Contractors, and the officials from the Host Country Government to publicly disclose specific details in your native language.
  • If you are unable to directly contact the Developers, Contractors, and/or the Host Country Government, reach out to a Community Leader or CSO/NGO for assistance.
• If you are unable to attend the project’s monitoring meetings, browse Financiers’, Developers’, Contractors’, and the Host Country Government’s websites for copies of project-specific environmental and social monitoring results, updates, and/or reports, as well as company- and/or institution-wide reports on accountability, sustainability or sustainable development, social responsibility, and/or finances for more information.
  • Bookmark the website(s) with these materials, so that you can easily find newer results, updates, and/or reports.
  • Save copies of these results, updates, and/or reports for future reference.
• Review Financiers’, Developers’, Contractors’, and Subcontractors’ compliance with governmental, industry-specific, and internal policies, procedures, and guidelines for monitoring and reporting on environmental, social, health, and safety risks.
  • Review Financiers’ compliance with CBIRC’s “Key Performance Indicators (KPIs) of Green Credit Implementation” and “Opinions on Green Credit Implementation.” Submit concerns or complaints about Financiers’ noncompliance with KPIs to CBIRC.
  • Review China International Contractors Association’s (CHINCA) “Guidelines of Sustainable Infrastructure for Chinese International Contractors” and “Community Engagement Handbook for Chinese International Contractors.” Submit concerns or complaints to CHINCA about Developers and Contractors that do not undertake proper monitoring.
  • Report major relevant situations or events, such as the failure to monitor and report on environmental and social performance, to the Chinese Ministry of Commerce (MOFCOM) and Ministry of Ecology and Environment (MEE) in a timely manner.
  • Check whether the Developers and Contractors are part of the Chinese SASAC negative list of overseas investment projects. Submit concerns or complaints about these Developers’ and Contractors’ noncompliance with host country requirements for monitoring to SASAC.
  • Check whether the Developers and Contractors are part of the Chinese MEE’s and Environment Protection Departments’ public “List of National Key Monitoring Enterprises” and list of companies that have discharged pollutants exceeding environmental standards or have been responsible for major, large-scale environmental pollution accidents.
  • Submit queries/concerns/complaints about noncompliance with other policies, procedures, or guidelines to the appropriate actor.

Hiring Experts and/or engaging Relevant Host Country Government Agencies to adopt a participatory approach toward monitoring during the project implementation and operations phases would:

• Advance high-quality development along the BRI.
• Align Financiers’, Developers’, and Contractors’ practices for BRI projects with Chinese policies and guidelines for project monitoring, as well as international best practices.
• Address critical gaps in compliance with host country laws, regulations, and procedures for effective environmental and social monitoring.
• Maintain regular contact between Developers, Contractors, Experts, and the Host Country Government on the one hand and local communities, CSOs/NGOs, and other third-party stakeholders on the other. Build strong relationships based on inclusive dialogue and constructive feedback.
• Increase transparency and accountability of project-related operations, especially surrounding the management of significant adverse impacts and risks during the project implementation and operations phases.
• Improve the overall quality of each monitoring report and project. Ensure local and Indigenous knowledge, expertise, and practices inform project decision-making, implementation, and operations.
• Drive people-oriented progress and further green development.
• Reduce the risk of protests, damage, or other forms of conflict during the project implementation and operations phases.
• Curb significant commercial costs from delays caused by social upheaval, especially during the project implementation and operations phases.

Preparing environmental and social monitoring reports that can be conveniently accessed at no cost to the public throughout the project life cycle would:

• Promote transparency and accountability of project-related operations.
• Fully inform key stakeholders of the progress and ongoing impacts of each project, as well as the environmental and social performance of Developers and Contractors.
• Build trust, understanding, and capacity among local communities, host country stakeholders, and other third-party stakeholders.
• Encourage the fulfillment of promises, commitments, and requirements on ESAM determined in the pre-project planning phase.
• Bolster Developers’ and Contractors’ annual company rankings or credit ratings for disclosing reports focused on environmental, social, and governance (ESG) factors of their projects.

• World Bank, “Asset Management of Environmental and Social Risks and Impacts,” in Environmental and Social Framework, p.27-28, 2017, View the PDF.

• International Finance Corporation (IFC), “Conservation Alliance’s Community Based Monitoring Protocol,” View the Website. 
• The Regional Environmental Center for Central and Eastern Europe, “Monitoring,” in EIA Training Resource Manual for South Eastern Europe, View the PDF.
• United Nations Environment Programme (UNEP), “Topic 11: Implementation and follow up,” in Environmental Impact Assessment Training Resource Manual, Second Edition, 2002, View the PDF.
• World Bank, “Good Practice Note: Third-Party Monitoring,” in Environment & Social Framework for IPF Operations, First Edition, June 2018, View the PDF.
• World Bank, “Technical Note: Third-Party Monitoring for Environmental and Social Risk Management and Benefit Sharing in Emission Reductions Programs,” Forest Carbon Partnership Facility (FCPF) and BioCF Initiative for Sustainable Forest Landscapes (ISFL), September 2021, View the PDF.

¹ State-owned Assets Supervision and Administration Commission of the State Council (SASAC), “Measures for the Supervision and Administration of Overseas Investment by Central Enterprises,” 2017.

² Ibid.

³ Ministry of Environment and Ecology (MEE), “Guiding Opinions on Promoting Investment and Financing to Address Climate Change,” 2020.

⁴ Ministry of Commerce (MOFCOM) and MEE, “New Guidelines for Green Development in Overseas Investment and Cooperation,” July 2021.

⁵ China Banking Regulatory Commission (CBRC) and China Insurance Regulatory Commission (CIRC) (now China Banking and Insurance Regulatory Commission (CBIRC)), “Key Performance Indicators of Green Credit Implementation,” 2014.

⁶ The following policies specifically refer to audits or assessments: Export-Import Bank of China (China Exim Bank), “White Paper on Green Finance and Social Responsibility,” 2019; China Banking Association (CBA), “Corporate Social Responsibility Guidelines,” January 2009; CBRC, “Notice of the China Banking Regulatory Commission on Issuing the Green Credit Guidelines,” 2012. The following policy broadly refers to environmental and social risk monitoring: CBRC and CIRC, “Guidelines on Regulating the Banking Industry in Serving Enterprises’ Overseas Development and Strengthening Risk Control,” January 2017.

⁷ Bank of China (Hong Kong) (BOCHK), “Sustainability Policy,” 2021.

⁸ CBRC and CIRC, “General Office of the China Banking Regulatory Commission Opinions on Green Credit Implementation,” 2013.

⁹ China Exim Bank, “White Paper;” China Exim Bank, “Guidelines for Environmental and Social Impact Assessment for Project Loans of the China Export and Import Bank,” 2007.

¹⁰ CBRC and CIRC, “Opinions on Green Credit.” 

¹¹ China Exim Bank, “White Paper.”

¹² China Chamber of Commerce Metals, Minerals and Chemicals Importers & Exporters (CCCMC), “Guidelines for Social Responsibility in Outbound Mining Investments,” 2017; State Forestry and Grassland Administration (SFGA), "Guidelines for Sustainable Silviculture for Chinese Companies Overseas," 2007; Sinohydro, “Occupational Health, Safety and Environmental Policy Statement,” 2013.

¹³ CCCMC, “Outbound Mining Investments.”

¹⁴ SynTao and China International Contractors Association (CHINCA), “Community Engagement Handbook for Chinese International Contractors-北京商道纵横信息科技有限责任公司,” 2021.

¹⁵ Sinohydro, “Occupational Health.”

¹⁶ CHINCA, “Guide on Social Responsibility for Chinese International Contractors,” September 2012; SFGA, "Silviculture for Chinese Companies."

¹⁷ SFGA, "Silviculture for Chinese Companies."

¹⁸ CHINCA, “Draft Revisions to Guide on Social Responsibility for Chinese International Contractors,” July 2021.

¹⁹ CCCMC, “Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains,” 2015.

²⁰ CCCMC, “Outbound Mining Investments.”

²¹ Sinohydro, “Environmental Protection Policy Statement,” 2017.

²² CCCMC et al., “Guidance for Sustainable Natural Rubber,” 2017.

²³ SFGA, "Silviculture for Chinese Companies."

²⁴ MOFCOM and MEE, “Guidelines for Environmental Protection in Foreign Investment and Cooperation,” 2013.

²⁵ Sinohydro, “Occupational Health.”

²⁶ SFGA, "Silviculture for Chinese Companies.”

²⁷ CCCMC, “Chinese Due Diligence.”

²⁸ CCCMC et al., “Sustainable Natural Rubber.”

²⁹ CCCMC, “Chinese Due Diligence.”

³⁰ National Development and Reform Commission (NDRC), “Code of Conduct for the Operation of Overseas Investments by Private Enterprises,” December 2017; CCCMC et al., “Sustainable Natural Rubber.”

³¹ CCCMC et al., “Sustainable Natural Rubber.”

³² SynTao and CHINCA, “Community Engagement Handbook.”

³³ Standing Committee of the National People's Congress, “Environmental Impact Assessment Law of the People's Republic of China,” October 2002.

³⁴ Standing Committee of the National People's Congress, “Revision of Environmental Protection Law of the People's Republic of China,” 2014.

³⁵ Ibid.

³⁶ State Council, “Regulations on Open Government Information of the People's Republic of China,” January 2007.

³⁷ Standing Committee, “Revision of Environmental.”

³⁸ Standing Committee, “Environmental Protection Law.”

³⁹ Standing Committee, “Revision of Environmental.”

⁴⁰ Standing Committee, “Environmental Protection Law.

⁴¹ MEE, “Amendment to the Regulations on Environmental Protection Management for Construction Projects,” November 2020.

⁴² Standing Committee, “Environmental Protection Law.”

⁴³ State Environmental Protection Administration of China (SEPA) (now MEE), “Measures on Open Environmental Information,” 2007.

⁴⁴ Ministry of Environmental Protection (MEP) (now MEE), “Notice on Further Strengthening the Disclosure of Environmental Protection Information,” October 2012.

⁴⁵ Ibid.

⁴⁶ Ibid.

47 "The Intergovernmental Panel on Climate Change," View the Website.

⁴⁸ International Best Practice is based on Asian Development Bank (ADB), "Safeguard Policy Statement," 2009; Asian Infrastructure Investment Bank (AIIB), "Environmental and Social Framework," 2021; AIIB, “Policy on Public Information,” September 2018; World Bank, "Environmental and Social Framework," 2018; Mekong Partnership for the Environment, "Guidelines on Public Participation in Environmental Impact Assessment in the Mekong Region," First Edition, 2017.