A/HRC/45/28 (d) Ensure that continued operations during the COVID-19 pandemic are safe and are in line with the good practices identified with respect to stakeholder engagement; concerning new projects approved during the COVID-19 pandemic, raise the bar as to the safety of stakeholders and the strict enforcement of applicable safeguards; (e) Provide adequate space and concrete support for community-led human rights due diligence; (f) Provide information on how financial intermediaries comply with the institutions’ safeguards; (g) Explicit recognize the right to access to information; (h) Enforce the presumption of proactive disclosure of information, with limited, specific exemptions; (i) Translate all documents in a language understood by affected communities; (j) Take proactive measures to prevent the occurrence of reprisals, systematically and publicly denounce instances of reprisals and push local authorities to investigate promptly and thoroughly such instances and bring the perpetrators to justice; (k) Give independent accountability mechanisms sufficient powers and resources and make their decisions enforceable; (l) Obtain consensus from the affected communities as to the design and membership of grievance mechanisms at the project level; (m) Conduct human rights impact assessments prior to imposing loan conditionalities that compel States to take retrogressive measures; (n) Embrace a human rights-based approach to combating corruption that focuses on the victim, State responsibility, prevention and redress; (o) Strengthen measures on governance reform in client countries; (p) Conduct robust anti-corruption due diligence processes; (q) Extend whistle-blower protection to external whistle-blowers when it is not yet in place; (r) Automatically flag instance of corruption to the national authorities and, as necessary, put pressure on them to take the required action; (s) Establish basic measures to ensure that the emergency funds given to States in the context of the COVID-19 pandemic are spent in a transparent and accountable manner; (t) Formally recognize the role of civil society as independent monitoring groups in the fight against corruption and strengthen their capacities in this respect. 74. The Independent Expert recommends that States: (a) Ensure a safe environment that is conducive to the participation of communities and civil society; (b) Promptly and thoroughly investigate instances of reprisals and bring the perpetrators to justice; (c) Allocate the maximum available resources to the progressive realization of human rights and avoid potential retrogression; (d) Conduct human rights impact assessments before considering taking retrogressive measures; (e) Systematically investigate international financial institutions; instances of corruption flagged by 19

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