Natural Justice welcomes the opportunity to comment on the first draft for consultation of the World Bank Environmental and Social Framework (“Draft ESF”). As we pointed out in our April 2013 Submission to the World Bank Safeguards Review, the Bank’s current environmental and social safeguard policies (“safeguard policies”) at one time established it as an international leader in reducing the negative effects of investment operations in developing countries. That is no longer the case, however, and the Bank’s review and update of its safeguard policies provides an opportunity for the Bank to bring its policies into line with environmental and human rights standards that are now broadly accepted.