Asia Society Policy Institute

For Overseas Projects:

The Chinese Government should:¹

• Improve environmental information disclosure to strengthen risk management for BRI and other overseas investment projects.

Local China Banking and Insurance Regulatory Commission (CBIRC) Offices should:²

• Disclose major environmental and social risks.

Financiers should:

• Designate specialized departments and/or personnel to be responsible for disclosing information related to overseas investments and handling public relations.³
  • Publish sustainable development or corporate social responsibility (CSR) reports on an annual or semiannual basis.⁴
  • Disclose information about how funds have been allocated to projects with major environmental and social impacts.
  • Review host country laws and regulations on the disclosure of financial information to ensure legal adherence.⁵
• Beginning in the pre-project planning phase for each project, communicate and interact with stakeholders “through various effective ways” to gather stakeholders’ suggestions and opinions on how to manage environmental and social risks.⁶
  • Disclose information related to environmental and social risks.⁷
• Work with Developers and Contractors to disclose the names of each project, its major Investors, and Contractors; the funding amount; and the environmental impact assessment (EIA) in a timely manner.⁸
• Work with the Chinese Government to incorporate companies’ environmental information into the financial credit information database, and share information for loan and investment decision-making processes.⁹

Developers and Contractors should:

• Designate specific personnel to be responsible for disclosing information about company operations and decisions in an accurate, complete, timely, and truthful manner.¹⁰
• Publish CSR or sustainability reports on an annual or semiannual basis.¹¹
  • Provide regular updates on their websites, share publications, and engage in other communication activities to improve social responsibility information disclosure.¹²
  • Disclose “sustainability governance rules and environmental protection units” on their websites and social media accounts.¹³
  • Release policies, plans, or strategies for respecting the culture and heritage of local communities, particularly Indigenous peoples.¹⁴
  • Clarify their own stance on issues that communities regard as important.¹⁵
  • Provide training to internal employees, Subcontractors, and other partners based on both the issues raised and the decisions made during meetings with communities and other host country stakeholders in order to ensure consistent messaging.¹⁶
  • Publicize major changes in their sustainability governance system on their websites and social media accounts.
  • See Project Monitoring and Reporting for more insight into the preparation of periodic reports.
• At the beginning of the pre-project planning phase, release information about payments made to the Host Country Government.¹⁷
• Establish a specific mechanism for disclosure of sustainability information to Affected People and other key stakeholders.¹⁸
  • Promptly disclose information about project plans, decisions, and activities with potential significant economic, social, and environmental impacts, as well as countermeasures to reduce risks to local communities, host country stakeholders, other third-party stakeholders, and their headquarters in China.¹⁹
  • Document and clearly communicate the “core messages of community engagement” including, but not limited to, relevant stakeholders, company positions, critical issues, and communication objectives.²⁰
  • Disclose information that they wish to share with communities, such as each project’s benefits to the local people or regulations for community members to follow.²¹
  • Disclose information that communities would be concerned about, such as adverse impacts of proposed projects, and plans for compensation, resettlement, livelihood restoration, and monitoring.²²
  • Review host country laws and regulations on information disclosure, and closely monitor implementation of their own practices to ensure complete legal compliance.²³
• Proactively report on management of social and environmental risks on their websites and social media accounts during the project implementation and operations phases.²⁴
• Share information about companies’ ethical, social, and environmental performance for specific projects in ways that would be appropriate and meaningful to Affected People and other key stakeholders.²⁵
• Promptly disclose major “pollution accidents” on their websites and social media accounts.²⁶

Financiers, Developers, and Contractors should:

• Disclose environmental, social, and governance (ESG) information annually to the Global Reporting Initiative (GRI).²⁷
• Continuously improve environmental information disclosure.²⁸

For Domestic Projects in China Only:

The Chinese Government should:²⁹

• Disclose details about the approval and implementation of major construction projects, among other government information that fulfills the following criteria:
  • Involves the vital interests of local people and organizations.
  • Needs to be known by the public or allow for their participation.
  • Shows the structure, function, working procedures, and other matters related to each administrative agency.
  • Should be disclosed on the administrative agency’s own initiative according to laws, regulations, and provisions.

Subnational Governments should:³⁰

• Disclose information such as:
  • Important and major matters in construction and management.
  • Information about the construction of social and public interest institutions.
  • Information about land requisition or appropriation, household demolition, and resettlement.

Chinese Environmental Protection Departments should:³¹

• Proactively disclose information such as:
  • Environmental protection laws, regulations, rules, standards, and plans.
  • Environmental statistics and environmental investigation information.
  • Emergency response plans and forecasts.
  • Major environmental emergencies.
  • Pollution targets and assessments.
  • Fees levied against Developers and Contractors for the discharge of pollutants.
  • A list of Developers and Contractors that have discharged pollutants exceeding environmental standards, or have been responsible for major, large-scale environmental pollution accidents.
  • Inspection and approval results of environmental protection projects.
• Coordinate and assess the disclosure of their environmental information.
• See Disclosure of Draft and Final Versions of ESIA and ESMP, Project Monitoring and Reporting, and Preparation and Implementation of Environmental and Social Action Plan (ESAP) for more information about the disclosure of documents related to the ESIA process.

Developers and Contractors should:³²

• Voluntarily disclose information such as:
  • Their environmental principles, targets, and results.
  • Investments in environmental protection.
  • The type, amount, toxicity, and destination of discharged pollutants.
  • The existence of environmental protection facilities for construction and operation.
  • The management of waste material.
  • Any agreement with an Environmental Protection Department to improve environmental conduct.

Financiers should:

• Disclose information about final agreements for proposed projects on their websites and social media accounts in Chinese, English, and local dialect(s) and language(s), including Indigenous and minority languages, as soon as possible.

Financiers, Developers, and Contractors should:

• Respond to all stakeholders’ requests for project-related information to be disclosed throughout the project life cycle.
  • When requested information cannot be disclosed, provide a written explanation of the reason(s) why this information cannot be disclosed.
  • Give Affected People and other key stakeholders the option to file an appeal for denials of disclosure. See Establishment and Maintenance of a Grievance Mechanism for more insight into appeals processes.
• At the beginning of the pre-project planning phase, work with National and Subnational Government Officials and CSOs/NGOs to identify stakeholders’ specific information needs related to ability, literacy, gender, mobility, and language.
  • Work with Interpreters or hire staff with fluency in the local dialect(s) and language(s), including Indigenous and minority languages, to communicate project information to local communities.
  • Arrange for appropriate methods to communicate with a wide range of stakeholders. Consider using nonwritten forms to facilitate understanding of scientific or technical information.
  • Publicize basic information in local media outlets.
  • Work with CSOs/NGOs to conduct outreach to local communities living around, in close proximity to, and within a project site.
  • Post information on their websites and social media accounts and at city/town/village/provincial halls in Chinese, English, and local dialect(s) and language(s).
  • Send a formal letter to each household occupying or using land in the project area of influence to inform them of the project.
  • When available, speak on the local community radio or post a message on the community advertising board.
• As early as possible, publicize information about:
  • The name, value, purpose, nature, and scale of each proposed project.
  • The location of project site(s) and other peripheries within the project area of influence.
  • The names of and contact information for Financiers, Developers, Contractors, and Subcontractors.
  • The implementation schedule, which outlines the duration of all proposed activities.
  • Potential risks and impacts in the form of an environmental and social impact assessment (ESIA).
  • Proposed mitigation measures in the form of an environmental and social management plan (ESMP).
  • The proposed process for stakeholder participation and consultation.
  • The proposed process for determining and providing compensation, resettlement, and livelihood restoration support.
  • The time(s) and venue(s) for public workshops, forums, consultations, and other meetings.
  • The process for notifying people of any meetings and key takeaways.
  • The process for formally lodging queries/concerns/complaints and seeking redress from relevant grievance mechanisms.
  • Major agreements and other important project documentation including, but not limited to, the land acquisition and resettlement plan (LARP), livelihood restoration plan (LRP), and Indigenous peoples plan (IPP).
• Allocate adequate time for initial sharing of information, meaningful consultation with all stakeholders, and decision-making.
  • Provide local communities adequate time to fully consider all of this information, discuss their options, and provide feedback directly or anonymously.
• Once the project design has been finalized and before construction begins, install and maintain their own signage with information about Financiers’, Developers’, Contractors’, Subcontractors’, and other stakeholders’ involvement in a clearly visible and understandable manner throughout project areas and peripheries.
• Disclose and/or update the previously-mentioned project information in appropriate languages through local media outlets and direct outreach, on their websites and social media accounts, and at city/town/village/provincial halls as soon as significant changes occur.³³

• Review Stakeholders to identify the appropriate website(s) and social media account(s) to browse for information that is either related or specific to a project.
  • Use a language interpretation tool such as Google Translate if the Stakeholder’s (e.g., Financier's, Developer's, Contractor's, Chinese Government Actor's, or CSO/NGO's) website is not available in your native language.
  • Financiers’, Developers’, and Contractors’ websites and social media accounts may include press/news releases about ongoing or proposed infrastructure projects; records or notices about project-related events and negotiations; policies on sustainable development, stakeholder engagement, and/or environmental and social assessment and management (ESAM); and reports on specific projects’ social and environmental impacts, as well as measures to manage these risks.
  • Chinese Ministries’, Regulators’, and Embassies/Consulates’, and the Host Country Government’s websites and social media accounts may include press/news releases about ongoing or proposed infrastructure projects; records or notices about project-related events and negotiations; Chinese and local laws and policies on sustainable development, stakeholder engagement, and/or ESAM; and reports on specific projects’ social and environmental impacts, as well as measures to manage these risks.
  • CSOs/NGOs’ and Research Institutions/Think Tanks’ websites and social media accounts may include information about the project or specific Financiers, Developers, and Contractors that are involved in the project.
  • Media Outlets’ websites and social media accounts may include article(s) about the project or specific Financiers, Developers, and Contractors that are involved in the project.
• Reach out to a Community Leader, CSO/NGO, Local Government Authority, or the nearest Chinese Embassy/Consulate for assistance in finding project-related information.
• If any of the above-mentioned project-related and Financier-, Developer, or Contractor-specific information cannot be found online, use either Stakeholders or a search engine such as Google to find the appropriate contact information for the Financier, Developer, or Contractor that you wish to reach.
  • Use available modes of contact to communicate with the Financier, Developer, or Contractor.
    • Written letters and faxes are often regarded as more formal and likely to trigger internal action, but you can also send emails or social media messages to ask questions, raise concerns, or request specific information.
  • If possible, visit the Financier’s, Developer’s, or Contractor’s office in your country.
• If you are unable to obtain the information that you are seeking, review laws and regulations on information disclosure in your country.
  • If the Financier, Developer, or Contractor has failed to comply with the relevant local laws and regulations, report this violation to the Relevant Industry Association or Regulator in China.
  • Consider filing an appeal for:
    • Contractors’ (and Subcontractors’) denials of disclosure to Developers.
    • Developers’ denials of disclosure to Financiers, China International Contractors Association (CHINCA), the Chinese Chamber of Commerce in your country, and Chinese Regulators; and
    • Financiers’ denials of disclosure to the China Banking Association (CBA) or Chinese Regulators.
• Look for signage posted by the Financiers, Developers, Contractors, and Host Country Government around the project site or at city/town/village/provincial halls.
  • Use your phone or a camera to take a picture of this signage for your own records, especially if you cannot understand the written language used.
  • Alternatively, write down all of the information conveyed on the signage.

Disclosing information about internal policies and procedures throughout the project life cycle would:

• Align Financiers’, Developers’, and Contractors’ practices for BRI projects with Chinese laws, policies, and guidelines on information disclosure, as well as international best practices.
• Increase transparency and accountability of overall operations.
• Build trust among local communities, host country stakeholders, and other third-party stakeholders.
• Facilitate local communities, host country stakeholders, and other third-party stakeholders’ understanding of Financiers’, Developers’, and Contractors’ roles, responsibilities, and priorities.
• Elevate China’s standing as a global source of Financiers, Developers, or Contractors for high-quality development.

Sharing project-specific information with local communities, host country stakeholders, and other third-party stakeholders throughout the project life cycle would:

• Foster mutual understanding and win-win cooperation between Financiers, Developers, and Contractors, on the one hand, and local communities, host country stakeholders, and other third-party stakeholders, on the other.
• Enhance collaboration by increasing the inclusivity and effectiveness of stakeholder consultation and participation.
• Address critical gaps in compliance with host country laws, regulations, and procedures related to information disclosure.
• Encourage the fulfillment of promises, commitments, and requirements determined in the pre-project planning phase.
• Improve the overall quality of each project. Ensure local and Indigenous knowledge, expertise, and practices inform project decision-making, implementation, and operations.
• 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.
• Bolster Developers’ and Contractors’ annual company rankings or credit ratings for observing host country laws and regulations, disclosing ESG information, and fulfilling other social responsibilities.

• Asian Development Bank (ADB), "Access to Information Policy," September 2018, View the PDF.
• Asian Infrastructure Investment Bank (AIIB), "Policy on Public Information," September 2018, View the PDF.
• International Finance Corporation (IFC), "Access to Information Policy," November 25, 2013, View the PDF.
• World Bank, "Bank Policy: Access to Information," July 1, 2015, View the PDF.

• World Bank, “ESS10: Stakeholder Engagement and Information Disclosure,” Guidance Note for Borrowers, Environmental & Social Framework for IPF Operations, June 2018, View the PDF.
• United Nations Development Programme (UNDP), “Supplemental Guidance: Disclosure of Project-related Social and Environmental Screenings, Assessments, and Management Plans,” May 2022, View the PDF.

¹ Ministry of Environmental Protection (MEP) (now Ministry of Ecology and Environment (MEE)), “The Belt and Road Ecological and Environmental Cooperation Plan,” May 2017.

² China Banking Regulatory Commission (CBRC) and China Insurance Regulatory Commission (CIRC) (now China Banking and Insurance Regulatory Commission (CBIRC)), “General Office of the China Banking Regulatory Commission Opinions on Green Credit Implementation,” 2013.

³ CBRC and CIRC, “Guidelines on Regulating the Banking Industry in Serving Enterprises’ Overseas Development and Strengthening Risk Control,” January 2017.

⁴ CBRC, “Key Performance Indicators of Green Credit Implementation,” 2014.

⁵ Ibid; CBRC and CIRC, “Notice of the China Banking Regulatory Commission on Issuing the Green Credit Guidelines,” February 2012.

⁶ CBRC, “Key Performance Indicators.”

⁷ CBRC and CIRC, “Guidelines on Regulating.”

⁸ Ibid.

⁹ People's Bank of China (PBOC), “Guidelines for Establishing the Green Financial System,” August 2016.

¹⁰ CBRC and CIRC, “Guidelines on Regulating.”

¹¹ China Chamber of Commerce Metals, Minerals and Chemicals Importers & Exporters (CCCMC), “Guidelines for Social Responsibility in Outbound Mining Investments,” 2017.  

¹² China International Contractors Association (CHINCA), “Guide on Social Responsibility for Chinese International Contractors,” September 2012.  

¹³ CHINCA and Dagong Global Credit Rating, “Guidelines of Sustainable Infrastructure for Chinese International Contractors (SIG),” 2017.

¹⁴ CCCMC, “Outbound Mining Investments.”

¹⁵ SynTao and 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.

¹⁶ Ibid.

¹⁷ CCCMC, “Outbound Mining Investments.”

¹⁸ CHINCA and Dagong Global Credit Rating, “Guidelines of Sustainable Infrastructure.”

¹⁹ CHINCA, “Draft Revisions to Guide on Social Responsibility for Chinese International Contractors,” July 2021; China-ASEAN Investment Cooperation Fund (CAF), “Social Responsibility and Environmental Protection Guidelines for Investments in the ASEAN Region,” 2014; State Forestry and Grassland Administration (SFGA), "Guidelines for Sustainable Silviculture for Chinese Companies Overseas," 2007; CCCMC et al., "Guidance for Sustainable Natural Rubber," 2017; CCCMC, “Outbound Mining Investments.”

²⁰ SynTao and CHINCA, "Community Engagement Handbook."

²¹ Ibid.

²² Ibid.

²³ Ibid.

²⁴ CCCMC, “Outbound Mining Investments.”

²⁵ CCCMC, “Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains,” 2015.  The following policy references the disclosure of information about social responsibility and performance: National Development and Reform Commission (NDRC) et al., “Code of Conduct for the Operation of Overseas Investments by Private Enterprises,” December 2017.

²⁶ CHINCA and Dagong Global Credit Rating, “Guidelines of Sustainable Infrastructure.”

²⁷ Green Finance Committee (GFC) of China Society for Finance and Banking et al., “Environmental Risk Management Initiative for China’s Overseas Investment,” September 2017; "Global Reporting Initiative (GRI)," View the Website. 

²⁸ Green Finance Initiative & GFC, "Green Investment Principles (GIP) for the Belt and Road," November 2018; CBRC and CIRC, "Opinions on Green Credit."

²⁹ State Council, “Regulations on Open Government Information of the People's Republic of China,” January 2007.

³⁰ Ibid.

³¹ State Environmental Protection Administration of China (SEPA) (now MEE), “Measures on Open Environmental Information (Trial),” February 2007; MEP, “Notice on Further Strengthening the Disclosure of Environmental Protection Information,” October 2012.

³² SEPA, “Open Environmental Information.”

³³ 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.