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Urgent Call for Conditionalities on New IFC and EBRD Loan to Oyu Tolgoi Mine

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Joint Statement

December 9, 2024

We, the undersigned civil society organizations (CSOs) and representatives of herders from Mongolia, strongly condemn the International Finance Corporation (IFC) and European Bank for Reconstruction and Development (EBRD) in providing a $100 million loan each, to Oyu Tolgoi (OT). This decision blatantly disregards years of unresolved grievances, environmental harm, and the failure of OT to comply with IFC and EBRD’s safeguard standards, as well as widespread rejection from local herders, CSOs, and even the Mongolian government.

Unresolved Harms and Non-Compliance

OT has failed to address critical issues, including its commitments under the 2017 Herders Complaint Resolution Agreements and IFC and EBRD’s social and environmental safeguards. Longstanding issues include:

  1. Failures in completing Resolution Agreements: Herders continue to struggle to sustain their livelihoods and protect the environment, as the agreements resulting from CAO complaints remain incomplete. The Tripartite Council (TPC), tasked with implementing the 2017 Agreements, has failed to ensure meaningful involvement of herders in safeguarding their rights and livelihoods.
  2. Tailings Storage Facility (TSF) Seepage: Despite implementing a Remedial Action Plan (RAP) as required by lenders to address the seepage from tailings cell 1 (TC1), OT has neither adequately mitigated the seepage nor transparently disclosed its full extent. Recent data reveals worsening water quality, with Total Dissolved Solids (TDS) levels rising dramatically downstream.
  3. Pasture and Water Scarcity: The mine’s expansion plans threaten vital grazing lands and water resources. Springs that once supported herders’ livelihoods have dried up, forcing herders to compete for limited resources. Moreover, the Dugat-Khaliv river, a key water source for herders, has been diverted around TC2 in a diversion channel without capacity to convey flood-level flows during rainy periods, leading to significant water loss for downstream herders.
  4. Environmental Failures: OT consistently fails to meet the design goal of 64% tailings solid content, resulting in inevitable seepage from the additional pressure exerted by excess water in the tailings cell. This and other design inefficiencies directly lead to massive water wastage estimated at up to $1.46 million per year.
  5. Inadequate Community Engagement: Herders were not meaningfully consulted about the RAP or OT’s expansion plans, violating IFC and EBRD principles of transparency and participation.

Water Mismanagement and Wastage

OT’s operations exacerbate water scarcity through inefficient tailings management. Water wasted due to tailings solids being below design criteria results in significant financial and environmental costs:

  • From 2013-2017, OT achieved 56% solids (8% below design standard), wasting $1.46 million worth of water annually. From 2018-2024, OT achieved nearly 60% solids (4% below design standard) on average, meaning OT wastes $730,000 annually on replacement water. OT has approximately wasted $12.41 million since 2017 from losing 248.2 million liters of water.
  • Oyu Tolgoi (OT) must attain the highest percentage of solid content as specified by its design criteria, 64%, to effectively prevent water scarcity in the South Gobi Desert and ensure improved water access for herders. While lenders argue that the 60-64% range meets the standard, 2012 ESIA states that “Final concentrate will be thickened to 65% solids” which proves otherwise. The TSF operating consistently below 60% results in excessive water waste, posing severe risks to the fragile desert ecosystem and the livelihoods of herders who rely on limited freshwater resources. Achieving the 64% target is not merely an option but a critical necessity to minimize environmental harm, optimize resource use, and uphold OT’s responsibility to local communities.
  • This inefficiency compounds the structural weakness of tailings dams, necessitating costly redesigns and increasing the risk of catastrophic failure. Concerns Over Project Categorization and Political Risks We are deeply concerned that IFC and EBRD categorized OT’s expansion as a Category B project, despite its significant and irreversible impacts on herders and the environment. This misclassification downplays the scale of the risks, undermining proper oversight. Additionally, the Mongolian government is in a disagreement on additional financing that will add more debt, and the Mongolian Parliament Resolution #103 requires an independent audit of underground mine cost overrun which has not been disclosed. Approving new financing in such a contentious political and social environment poses significant risks to the project’s viability.

Recommendations and Conditionalities

IFC and EBRD must impose strict conditionalities on OT before any disbursements begin and ensure the conditionalities are placed in the lending agreement, including:

  1. Fulfillment of Past Commitments:
    • Include the 2017 Herders Complaint Resolution Agreements (HCRAs) in lenders’ compliance requirements and fully implement them.
    • Amend the RAP to include routine medical assessments for herders and their animals impacted by the contaminated water from the TSF seepage, and update Stakeholder Engagement Plan to involve the wider herder community impacted by the seepage.
    • Disclose all the important data from the attachments and annexes of the RAP.
  2. Water and Tailings Management Improvements:
    • Achieve the 64% as the highest solid content target for tailings as per the original ESIA.
    • Disclose the full extent of TSF seepage impacts, including chemical contamination and health risks.
  3. Protection of Herders’ Livelihoods:
    • Permanently halt land acquisitions that displace herders and prioritize using existing lease areas for future tailings cells.
    • Construct a permanent Dugat-Khaliv diversion channel based on maximum flood probabilities.
  4. Transparency and Meaningful Engagement:
    • Disclose all environmental and social impact assessments (ESIA) for expansion plans, implementation of the ESAP from the initial OT project loan, and OT Green Investment Plan.
    • Take actions to strengthen TPC functions through assessing TPC Charter and the implementation of the HCRAs
    • Ensure meaningful consultation with affected communities on all project aspects. This includes consultations on the expansion plans, environmental and social assessment related documents and strengthening of the Tripartite Council with valid herder representation as the body responsible to address herders’ concerns around the OT project.

The approval of new financing to OT without addressing these critical issues perpetuates harm to herders and the environment while eroding public trust in IFC’s and EBRD’s commitment to sustainable development. We call on IFC and EBRD to uphold their safeguards and suspend agreement signing and financing until OT achieves full compliance and fulfills its obligations to herders and the environment.

(Link to full statement in English and Mongolian)

Contact Information:
Sukhgerel Dugersuren, Oyu Tolgoi Watch, 976-99185828, otwatch@gmail.com
Battsengel Lkhamdoorov, Gobi Soil, 976-88705595, tsengel_5595@yahoo.com
Julio Castor Achmadi, Accountability Counsel, julio@accountabilitycounsel.org
Nina Lesikhina, Bankwatch Network, ninalesikhina@bankwatch.org

Signatories:
Gobi Soil, Mongolia
Oyu Tolgoi Watch, Mongolia
Center for Human Rights and Development, Mongolia
AFE, Mongolia
APPDO, Mongolia
CA NGO, Mongolia
GFS, Mongolia
MFSW, Mongolia
RwB Mongolia
SR NGO, Mongolia
SWA, Mongolia
SWB NGO, Mongolia
Accountability Counsel
CEE Bankwatch Network, Regional
Bank Climate Advocates, USA
Bank Information Center, USA
Both ENDS, the Netherlands
Center for Community Mobilization and Support, Armenia
Centre for Research and Advocacy, Manipur, India
Earth Thrive, UK/Serbia
Friends with Environment in Development (FED), Uganda
GAIA, Regional
Gender Action, USA
Green Advocates
Initiative for Right View (IRV), Bangladesh
International Accountability Project
INWOLAG
Kazakhstan International bureau for human rights, Kazakhstan
London Mining Network
LSD, Senegal
NGO Forum on ADB, Regional
Peace Point Development Foundation-PDF, Nigeria
Recourse
Samata & mm&P, India
Sinergia Animal, Brazil
Urgewald, Germany
Witness Radio, Uganda.

Source: Accountability Counsel.

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NGO WORK

Climate wash: The World Bank’s Fresh Offensive on Land Rights

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Climate wash: The World Bank’s Fresh Offensive on Land Rights reveals how the Bank is appropriating climate commitments made at the Conference of the Parties (COP) to justify its multibillion-dollar initiative to “formalize” land tenure across the Global South. While the Bank claims that it is necessary “to access land for climate action,” Climatewash uncovers that its true aim is to open lands to agribusiness, mining of “transition minerals,” and false solutions like carbon credits – fueling dispossession and environmental destruction. Alongside plans to spend US$10 billion on land programs, the World Bank has also pledged to double its agribusiness investments to US$9 billion annually by 2030.

This report details how the Bank’s land programs and policy prescriptions to governments dismantle collective land tenure systems and promote individual titling and land markets as the norm, paving the way for private investment and corporate takeover. These reforms, often financed through loans taken by governments, force countries into debt while pushing a “structural transformation” that displaces smallholder farmers, undermines food sovereignty, and prioritizes industrial agriculture and extractive industries.

Drawing on a thorough analysis of World Bank programs from around the world, including case studies from Indonesia, Malawi, Madagascar, the Philippines, and Argentina, Climatewash documents how the Bank’s interventions are already displacing communities and entrenching land inequality. The report debunks the Bank’s climate action rhetoric. It details how the Bank’s efforts to consolidate land for industrial agriculture, mining, and carbon offsetting directly contradict the recommendations of the IPCC, which emphasizes the protection of lands from conversion and overexploitation and promotes practices such as agroecology as crucial climate solutions.

Read full report: Climatewash: The World Bank’s Fresh Offensive on Land Rights

Source: The Oakland Institute

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NGO WORK

Africa’s Land Is Not Empty: New Report Debunks the Myth of “Unused Land” and Calls for a Just Future for the Continent’s Farmland

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A new report challenges one of the most persistent and harmful myths shaping Africa’s development agenda — the idea that the continent holds vast expanses of “unused” or “underutilised” land waiting to be transformed into industrial farms or carbon markets.

Titled Land Availability and Land-Use Changes in Africa (2025), the study exposes how this colonial-era narrative continues to justify large-scale land acquisitions, displacements, and ecological destruction in the name of progress.

Drawing on extensive literature reviews, satellite data, and interviews with farmers in Zambia, Mozambique, South Africa, and Zimbabwe, the report systematically dismantles five false assumptions that underpin the “land abundance” narrative:

  1. That Africa has vast quantities of unused arable land available for cultivation

  2. That modern technology can solve Africa’s food crisis

  3. That smallholder farmers are unproductive and incapable of feeding the continent

  4. That markets and higher yields automatically improve food access and nutrition

  5. That industrial agriculture will generate millions of decent jobs

Each of these claims, the report finds, is deeply flawed. Much of the land labelled as “vacant” is, in reality, used for grazing, shifting cultivation, foraging, or sacred and ecological purposes. These multifunctional landscapes sustain millions of people and are far from empty.

The study also shows that Africa’s food systems are already dominated by small-scale farmers, who produce up to 80% of the continent’s food on 80% of its farmland. Rather than being inefficient, their agroecological practices are more resilient, locally adapted, and socially rooted than the industrial models promoted by external donors and corporations.

Meanwhile, the promise that industrial agriculture will lift millions out of poverty has not materialised. Mechanisation and land consolidation have displaced labour, while dependency on imported seeds and fertilisers has trapped farmers in cycles of debt and dependency.

A Continent Under Pressure

Beyond these myths, the report reveals a growing land squeeze as multiple global agendas compete for Africa’s territory: the expansion of mining for critical minerals, large-scale carbon-offset schemes, deforestation for timber and commodities, rapid urbanisation, and population growth.

Between 2010 and 2020, Africa lost more than 3.9 million hectares of forest annually — the highest deforestation rate in the world. Grasslands, vital carbon sinks and grazing ecosystems, are disappearing at similar speed.

Powerful actors — from African governments and Gulf states to Chinese investors, multinational agribusinesses, and climate-finance institutions — are driving this race for land through opaque deals that sideline local communities and ignore customary tenure rights.

A Call for a New Vision

The report calls for a radical shift away from high-tech, market-driven, land-intensive models toward people-centred, ecologically grounded alternatives. Its key policy recommendations include:

  • Promoting agroecology as a pathway for food sovereignty, ecological regeneration, and rural livelihoods.

  • Reducing pressure on land by improving agroecological productivity, cutting food waste, and prioritising equitable distribution.

  • Rejecting carbon market schemes that commodify land and displace communities.

  • Legally recognising customary land rights, particularly for women and Indigenous peoples.

  • Upholding the principle of Free, Prior, and Informed Consent (FPIC) for all land-based investments.

This report makes it clear: Africa’s land is not “empty” — it is lived on, worked on, and cared for. The future of African land must not be dictated by global capital or outdated development theories, but shaped by the people who depend on it.

Download the Report

Read the full report Land Availability and Land-Use Changes in Africa (2025) to explore the evidence and policy recommendations in detail.

Source: Alliance for Food Sovereignty in Africa (AFSA)

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NGO WORK

Discover How Foreign Interests and Resource Extraction Continue to Drive Congo’s Crisis

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Whereas Donald Trump hailed the “peace” agreement between Rwanda and DRC as marking the end of a deadly three-decade war, a new report from the Oakland Institute, Shafted: The Scramble for Critical Minerals in the DRC, exposes it as the latest US maneuver to control Congolese critical minerals.

Under the Guise of Peace

After three decades of deadly wars and atrocities, the June 2025 “peace” deal between Rwanda and the Democratic Republic of the Congo (DRC) lays bare the United States’ role in entrenching the extraction of minerals under the guise of diplomacy. For decades, US backing of Rwanda and Uganda has fueled the violence, which has ripped millions of Congolese lives apart while enabling the looting of the country’s mineral wealth. Today, Washington presents itself as a broker of peace, yet its longstanding support for Rwanda made it possible for M23 to seize territory, capture key mining sites, and forced Kinshasa to the negotiation table with hands tied behind its back. By legitimizing Rwanda’s territorial advances, the US-brokered agreement effectively rewards aggression while sidelining accountability, justice for victims, and the sovereignty of the Congolese people.

The incorporation of “formalized” mineral supply chains from eastern DRC to Rwanda exposes the pact’s true aim: Securing access to and control over minerals under the guise of diplomacy and “regional integration.” Framed as peacemaking, this is part of United States’ broader geopolitical struggle with China for control over critical resources. Far from fostering peace – over a thousand civilians have been killed since the deal was signed while parallel negotiations with Rwanda’s rebel force have collapsed – this arrangement risks deepening Congo’s subjugation. Striking deals with the Trump administration and US firms, the DRC government is surrendering to a new era of exploitation while the raging war continues, driving the unbearable suffering of the Congolese people.

Introduction

The conflict in eastern DRC, which dates back three decades to the aftermath of the 1994 Rwandan genocide and subsequent Congo Wars, has claimed over six million lives, displaced millions more, and inflicted widespread suffering. Since late 2021, Rwanda and its proxy militia, M23, have stormed through mineral-rich lands and regional capitals, inflicting brutal violence and triggering mass displacement. While billions of dollars in natural resources are extracted from the area, Congolese communities toil in extreme poverty.

On June 27, 2025, a “peace” agreement was signed between Rwanda and the DRC under the auspices of the Trump administration, with diplomatic assistance from Qatar.1 The deal included pledges to respect the territorial integrity of both countries, to promote peaceful relations through the disarmament of armed groups, the return of refugees, and the creation of a joint security mechanism. A key clause commits the countries to launch a regional economic integration framework that would entail “mutually beneficial partnerships and investment opportunities,” specifically for the extraction of the DRC’s mineral wealth by US private interests.

Placing the deal in a historical perspective – after three decades of conflict and over seven decades of US chess game around Congolese minerals – this report examines its implications for the Congolese people as well as the interests involved in the plunder of the country’s resources.

The report begins by retracing 30 years of war, fueled by the looting of Congo’s mineral wealth and devastating for the people of eastern DRC. It then examines how US policy in Central Africa, from the Cold War to the present, has been shaped by its interest in Congolese minerals, sustained alliances with Rwanda and Uganda, and a consistent pattern of overlooking atrocities in support of these allies.

The report then analyses the implications of the regional economic integration aspect of the deal, which aims to link mineral supply chains in the DRC and Rwanda with US investors. The last sections examine the prospect for lasting peace and security resulting from the deal and the impact of growing involvement of US private actors in DRC and Rwanda.

Original Source: Oakland Institute

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