A joint-letter signed by 19 civil society organisations and labour unions has made the following recommendations to the European Investment Bank as it begins the second phase of deliberations for its Climate Bank Roadmap:

Industry support and criteria for counterparties

1. Build on and strengthen the existing PATH Framework to enhance the sustainability reporting, climate criteria and transition plans of supported companies. Ensure that
   climate criteria for companies are fully Paris aligned, exemptions to comply with these criteria are taken away and ensure client companies’ transition plans lead to a swift phase out of fossil fuels and CO2 emissions, which should include introducing a binding suspension clause to stop financing when the targets are not met. Finally, criteria for financial intermediaries should include, but go beyond the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD) and include criteria limiting and phasing out investments in fossil fuels.
2. Ensure that support for industry also meets the stated goal of ‘inclusive prosperity’, which should encompass pursuing positive social positive impacts in all climate
   finance. For this, the PATH framework should be further strengthened to also include broader environmental and social conditionalities for counterparties including both
   corporates and financial intermediaries to reduce resource - and energy use and ensure public interest. Clients’ business models and activities, including clean tech
   development, should contribute to affordable and environmentally-friendly access to essential services such as clean public transportation, job quality, sustainability, and enable technology transfer outside of the EU. It should also distribute funding fairly within the EU to avoid deepening internal inequalities.
3. Ensure that these environmental and social conditionalities lead beneficiaries of financial support to demonstrate a high reinvestment rate into decarbonisation, clean
   technologies and proven sustainable solutions that provide public benefits.
4. Recognise and empower the public sector (the main recipient of its climate finance) in providing effective climate solutions at scale and increased affordability. Support
   democratically governed public energy companies with strong climate plans which can help achieve a faster, more efficient and more affordable energy transition.

Climate targets and Implementing framework

1. Increase climate and environmental finance targets by following the example of the Asian Development Bank and increasing the threshold towards at least 75%.
2. Strengthen and adapt the existing climate finance methodology to stop its support for projects extending the life of fossil fuels and other highly polluting activities,
   including Carbon Capture and Storage (CCS), motorways, highways, port and airport expansions, industrial livestock farming and biofuels. Adopt strict criteria for hydrogen, bioenergy and hydropower. Do not support fossil based hydrogen and ensure that only hydrogen produced using renewable energy is supported and only when it is proven to be the most efficient option, it is produced for local use and does not divert renewable energy from direct electricity needs.
3. Ensure a robust implementation of the DNSH principle as a member of the EU Platform of Sustainable Finance across all financed projects.
4. Promote the thorough adoption of the New Collective Quantified Goal and the Common Approach to Measuring Climate Results to redirect increasing resources to
   low-income countries in the Global South (chiefly Least Developed Countries) through increasing highly concessional loans that implement human rights due diligence.
5. Enhance the transparency of the Climate Risk Assessment system by explaining its use in more detail and making the methodology publicly available to strengthen
   accountability and build trust. The updated Roadmap should include information related to the announced Biodiversity Risk Assessment system. Moreover, strengthen the transparency and accessibility of data on the EIB’s climate action and environmental sustainability (CA&ES) lending by disclosing sectoral and regional finance data, shortening the publication delay, and improving reporting on the use of EU programmes such as the Just Transition Fund and InvestEU.
6. Enhance transparency by disaggregating all spending and discloses financing volumes by project type in line with its own sectoral methodology for climate action
   and environmental sustainability. Moreover, the EIB should provide more visibility to its CA&ES spending on its website and reduce the time lag between intervention and reporting data.
7. Increase adaptation finance. As the impacts of climate change worsen, this becomes increasingly important. The vast majority of estimated adaptation needs in developing countries are typically publicly funded with a small proportion of commercially viable adaptation opportunities typically concentrated in agriculture, water and
   infrastructure. The bank should increase its target to match the ambition of other MDBs on adaptation finance, towards a 50% adaptation target.

Just transition

1. Prioritise a just transformation with a holistic approach across sectors to cover all regions. This should include targeted financing based on social needs for sustainable solutions, a balanced geographical spread inside the EU and more resources for low-income countries outside the EU. Moreover, all projects should be checked to ensure any climate finance is compatible with the needs for a just transition that respects human rights and protects the environment.
2. Make a plan to support public actors, especially local governments, to provide essential green public services in key sectors, such as sustainable and affordable housing, energy and transport. This could be done by adapting and expanding the Public Sector Loan Facility. In the housing sector, the Bank should improve its definition of affordable housing to target those most in need, limit the role of for-profit investors and ensure sufficient funds are available for the housing needs of lowest incomes. In the transport sector, this could be done by prioritising support for collective mobility, including public transport, biking infrastructure, social EV-leasing and car-sharing schemes.
3. Provide climate finance outside the EU in the form of increased concessional loans for projects with high development additionality that tackle energy poverty, transfer technology and prioritise high added value in the local economy, job creation and support for local communities, while respecting human rights and protecting the environment. This should include improving its human rights due diligence and project assessments and increasing support for the Least Developed Countries.
4. The clean tech strategy of the EU is also linked to acquiring more access to critical raw materials. The EIB should first of all pursue resource efficiency by supporting the scaling up of Europe’s recycling industry and reserve support for battery and EV production that minimises environmental impacts and the needs for raw materials. Any mining projects must come with high social and environmental safeguards inside and outside the EU, including protections against displacement, land grabs, local water pollution and deforestation. In the past some mining projects financed by the EIB have led to serious human rights and environmental violations. The Bank should strengthen its human rights and environmental due diligence - which is currently weaker than its MDB peers - before financing any mining project.

Read the letter in full