In 2013 and 2016, IFC invested a total of US$13.5m equity in NewGlobe Schools, Inc., which owned Bridge International Academies ("Bridge"), Africa’s largest chain of low-cost schools. According to IFC, at the time of its investment, Bridge operated 211 schools serving over 57,000 students in Kenya and aimed to provide quality education to children from families earning less than $2 per person per day. The investment was intended to support an increase in the number of schools in Kenya and expansion to 3 new countries.

IFC exited its investment in NewGlobe Schools, Inc. (the parent company of Bridge International Academies) effective March 3, 2022.

In April 2018, CAO received a complaint from the East Africa Centre for Human Rights, a Kenyan NGO, on behalf of current and former parents and teachers regarding IFC’s investment in Bridge schools in Kenya (Bridge-01). The Bridge-01 complaint was transferred to CAO’s compliance function for appraisal and CAO initiated a compliance investigation in October 2019.  During the investigation, CAO staff traveled to Kenya where the team spoke with complainants and community members, as well as client representatives and local authorities. In discussion with CAO, community members raised concerns regarding child sexual abuse and other child safeguarding issues at Bridge schools in Kenya. This resulted in two subsequent complaints to CAO (see Bridge-02 and Bridge-03) and in September 2020, CAO’s Vice President initiated a compliance appraisal specifically to consider the child sexual abuse issues.  In October 2023, CAO accepted four further complaints raising allegations of child sexual abuse at Bridge schools in Kenya (see Learn Capital-01, 02, 03 and 04).

CAO finalized its appraisal report in December 2020 finding that an investigation was merited, and initiated the investigation in January 2021.

CAO completed the investigation and submitted its report to the Board on October 3, 2023.  The investigation found that IFC failed to satisfy its environmental and social requirements under the Sustainability Policy and Performance Standards 1 and 4 on Assessment and Management of Environmental and Social Risks and Impacts, and Community Health, Safety, and Security, respectively.  Specifically, during IFC’s environmental and social due diligence prior to investing in Bridge, CAO found that IFC did not consider the project’s potential child sexual abuse risks or consider the capacity of its client to satisfy environmental and social requirements in relation to child sexual abuse risks and impacts. During supervision, IFC failed to regularly monitor or substantively address project-related child sexual abuse and gender-based violence (GBV) risks and impacts with its client. IFC’s supervision of child sexual abuse risks and impacts improved after CAO provided information about related incidents linked to Bridge and subsequently reported this information to IFC in February 2020. However, CAO found that IFC’s supervision efforts continued to fall short of its obligations, as IFC failed to ensure it received all required information nor took adequate steps to guarantee the client’s child protection and safeguarding approach was consistent with the Performance Standards. Prior to exiting the investment, IFC failed to work with the client to address child sexual abuse risks and impacts as required by the Sustainability Policy.

CAO’s report includes seven project-specific and institutional-level recommendations for IFC:

1. Remediation for survivors of child sexual abuse – IFC should work with Bridge to establish a facility to support a claims process for survivors and their families to receive remedy, including counseling, healthcare support, community reintegration support, funding and referrals to legal services, a mechanism that allows survivors to come forward, and financial compensation, as appropriate.
2. Strengthen community response to child sexual abuse and GBV against children within project communities.
3. Undertake a review of its portfolio to identify all projects where children are a vulnerable and disadvantaged subset of affected communities to identify and assess if appropriate social risk management measures are in place and operationalized.
4. Strengthen and clarify E&S provisions concerning children, as well as gender- and sex-differentiated harm, within the Sustainability Framework.
5. Undertake institution-wide capacity building efforts to prevent child sexual abuse and overlapping forms of GBV from occurring in its investment projects.
6. Establish a global GBV task force to advise IFC.
7. Clarify expectations for project compliance with Performance Standards when planning an exit.

In response, IFC submitted its management report, including a Management Action Plan (MAP), to the IFC Board on December 19, 2023.  On January 25, 2024, the Board held a meeting on the CAO investigation report, and IFC management report and action plan. Bank Group management and IFC’s Board of Executive Directors released a statement after the meeting extending the timeframe to consider the action plan by a month.

IFC submitted a revised management report and MAP on March 7, 2024, which was approved by the Board on March 13, 2024. It outlines several commitments and improvements in response to CAO's recommendations:

• IFC will directly fund a remediation program for survivors of child sexual abuse in counties where Bridge operated or currently operates in Kenya. The funding will be for a minimum of 3 years and a maximum of 10 years, to be adjusted based on outcomes of the design phase.
• Financial support with the objective of enabling survivors of child sexual abuse to access the services covered in the program would be provided, on a case-by-case basis, as needed, after careful assessment.
• The remediation program will be complemented by prevention activities aiming to engage local communities and services in counties in Kenya where Bridge operated or currently operates.
• Both the remediation and prevention programs will be informed by survivor-centered stakeholder engagement during design and implementation and the input of an advisory committee which will include relevant international and local GBV and child protection experts that are internal and external to the World Bank Group.
• IFC is undertaking a review of its portfolio to identify child sexual abuse and GBV risks and determine appropriate risk-management measures when needed. Progress on this review will be included in the first progress report on implementation of the Management Action Plan in a manner that complies with IFC’s Access to Information Policy.
• IFC is reviewing the E&S provisions in template investment agreements and will develop covenants to be included where appropriate in relation to child protection and GBV prevention and notification by clients of related incidents.
• IFC is building its capacity—through hiring GBV experts, delivering staff training, and developing tools—to address and prevent GBV in projects. IFC will issue and operationalize a statement to staff on zero tolerance for inaction on, or reprisals for, addressing GBV or child protection issues.

Separately from the Management Action Plan, IFC has committed to strengthen child protection provisions when it updates its Sustainability Framework and will consider GBV and child protection in the implementation of its Responsible Exit Approach. IFC will return to the Board for a meeting within six months to provide an update on progress and the final design of the remediation program based on consultation with stakeholders, and, if needed, make adjustments.

CAO Investigation Report is available in English, and the executive summary is available in Swahili under the 'Case Documents' section below.

On October 07, 2024, IFC distributed its first Management Progress Report on the implementation of the Management Action Plan (MAP) to the Board. The Progress Report, which outlines the status of IFC’s actions related to the in-country remediation and prevention program and institutional strengthening, is available in English.