Performance Standard 8 –
Cultural Heritage
Stakeholder Feedback
Frequently Asked Questions
How does the mitigation hierarchy apply to PS
8? How do you “restore” loss of cultural value?
What are the client’s responsibilities when the
location of investment is a site of cultural
heritage?
Comments
Areas of cultural heritage and rich biodiversity
sites should be no-go development areas.
Exclude religious and cultural important areas
from IFC's investments.
Include indigenous peoples’ sacred sites as
cultural heritage.
Note: IFC’s responses to questions and comments are based on the current draft (Version 2) of IFC’s
Sustainability Framework. They are subject to change as the Framework is further revised. No text in
the Framework or in these interim comments and responses is final until approved by IFC’s
Management and Board.
IFC Response
The mitigation hierarchy is more complex in PS 8 than for other
Performance Standards precisely because some cultural heritage
is irreplaceable. Where cultural heritage is irreplaceable, the client
must show that there is no other alternative, that the benefits of
the project outweigh the loss of the cultural heritage, and that the
cultural heritage is removed according to best available technique
(this is focused on archaeological sites). Where the cultural
heritage is considered critical, the client must meet an even higher
standard, possibly including good faith negotiations. Only if
neither of these circumstances applies would the mitigation
hierarchy apply.
Note that the policy is a ‘physical cultural heritage’ policy. Loss of
cultural value would have to be directly tied to the loss of
something physical. In many cases, the aspect of cultural value of
a physical object can be moved, while the object itself is affected.
The client will need to carry out a social and environmental
assessment of the project impacts, including the impacts on the
cultural heritage. Based on this assessment, the client should
determine whether the cultural heritage can be protected in place
or, if it needs to be moved, whether it is irreplaceable. Finally, the
client would need to identify any instances of critical cultural
heritage. The client’s responsibilities would then be determined
based on the answers to these questions.
The Performance Standards leave open the possibility that the
people who use the cultural heritage for long standing cultural
purposes may want to develop the area or aspects of the cultural
heritage. The Performance Standard also leaves open the
possibility that some development projects may ultimately provide
financial support for the preservation and protection of the cultural
heritage. In these respect, PS 8 takes the approach of evaluating
positive and negative impacts of the actual project rather than
identifying no go areas. This evaluation may lead to a no-go
project scenario.
For the same reasons as above, PS 8 looks at actual project
impacts rather than trying to identify areas for protection.
Based on the standard definition of a ‘site’ being something
physical, indigenous peoples’ sacred sites are already considered
cultural heritage. This definition of site could include such places
as Māori wāhi tapu, where the sacredness of the site may not be
physically evident to those who do not know its history.