Armenian NGOs have appealed to the European Bank for Reconstruction and Development (EBRD) to adhere to the principles of responsibility in its policies regarding the Amulsar mining project.
The European Bank for Reconstruction and Development (EBRD) has adhered to an environmentally sound course of action through adopting environmental and social policies and standards. The current Environmental and Social Policy (passed in 2024) contains a comprehensive set of environmental and social requirements (ESR) for its projects, which include ESR 1: Assessment and management of environmental and social risks and impacts; ESR 2: Labour and working conditions; ESR 3: Resource efficiency and pollution prevention and control; ESR 4: Health, safety and security; ESR 5: Land acquisition, restrictions on land use and involuntary resettlement ESR 6: Biodiversity conservation and sustainable management of living natural resources; ESR 7: Indigenous Peoples; ESR 8: Cultural heritage; ESR 9: Financial intermediaries; and ESR 10: Stakeholder engagement.
These requirements are fully applicable to EBRD’s “direct investments” and partially to “financial intermediaries” (clients are required to comply with ESR 2, ESR 4 and ESR 9, and cases of Category A projects - with ESRs 1 to 8 and 10). According to article 7.11, “Where the Bank’s investment is not directed at a specific project or physical assets, such as working capital finance, some types of equity investment and capital market transactions, or will lead to future investments, the proposed use of proceeds and the environmental and social footprint of the project may be largely indeterminate at the time of the EBRD’s decision to invest. In such cases, the Bank will: (i) assess the project based on the risks and impacts inherent in the particular sector and the context of the business activity, and (ii) assess the client’s environmental and social risk-assessment approach, including the environmental and social management systems (ESMSs) adopted, as well as its capacity and commitment to managing the environmental and social risks and impacts in accordance with the ESRs.“ According to article 7.12 “When assessing the EBRD's investments in other financial instruments, alternative risk assessment frameworks that are compatible with the Bank’s Environmental and Social Policy may be considered, while also taking into account the capacity of the client to implement such frameworks. The use of proceeds may be subject to environmental and social risk screening and assessment under the client’s ESMS. This system may be accepted by the Bank if it is suitably aligned and maintained, in accordance with the objectives of the ESRs.“ According to 7.13, “Where the project involves general corporate finance, working capital or equity financing for a multi-site company, and where the use of proceeds is not directed at specific physical assets, the client will be required to align its corporate ESMSs with the ESRs and develop measures at the corporate level to manage the environmental and social risks associated with its business activity“. According to 7.19, for “direct investments” and “financial intermediary” projects, “the EBRD will conduct due diligence on the client and its portfolio to assess: (i) the client’s existing environmental and social policies and procedures and its capacity to implement them; (ii) the environmental and social risks and impacts associated with the client’s existing portfolio and expected future projects; and (iii) any measures necessary to strengthen the client’s existing ESMS.“
EBRD’s Armenia Country Strategy 2025-2030 sets forth priorities for 2025-2030, which intends “to support the development of a more inclusive and competitive private sector” and “to accelerate the green economy transition through support for sustainable infrastructure”. It requires assessment of direct, indirect and cumulative impacts of projects, ensuring that financial intermediary partners have adequate environmental and social capacity and risk management procedures in place. Through technical cooperation EBRD intends to seek opportunities to build capacity within the public and private sectors, develop new environmental and social initiatives, and promote best practices aimed at addressing national, systemic environmental and social issues, etc..
In spite of the above-mentioned environmental and social policy regulations aimed towards better environmental and social performance, EBRD’s actual work on the ground in Armenia appears to contradict the stated priorities and commitments. This particularly relates to controversial mining operations, particularly in Amulsar, indirectly involving the Bank and its reputation.
On February 27, 2025, Government of Armenia adopted decision 220-A to provide financial guarantees to five private banks in Armenia (Ardshinbank CJSC, Acba Bank CJSC, ID Bank CJSC, Inecobank CJSC and Evocabank CJSC) to facilitate the funding of the notorious Amulsar gold mining project in Vayots Dzor. This decision was taken to the administrative court by three Armenian non-governmental organizations and ten citizens to challenge the legality of decision-making. None of the banks mentioned in the decision officially agreed to take part in the controversial project. In early May, 2025, the government modified the text of the decision by replacing the names of the mentioned banks with Ameriabank CJSC. The latter provided a 150 mln USD loan for funding the Amulsar project and currently intensive construction goes on the mountain to prepare the site for the mining.
Review of Ameriabank CJSC shareholders shows that 10% of its equities belong to the EBRD. Also, in May 2025, at its annual meeting in London, the EBRD announced a new agreement with Ameriabank. This means that EBRD is in a position to be accountable for the environmental and social impacts of the activities of Ameriabank as part of its post-investment responsibility.
Still on 15 July, 2025, civil society organizations in the country issued a call addressing the EBRD to engage in dialogue with its Armenian banking partners and to share its experience with the Amulsar project, including the reasons for its withdrawal and the significant environmental and social risks involved. We also urged the EBRD to ensure that its financing to Armenian banks does not directly or indirectly support the Amulsar mine. These actions could possibly prevent the support of the environmentally and socially disastrous project, however this was apparently not done.
We find it appropriate to remind the audience about the failures of the Armenian government and the illegal and irresponsible decision of the Armenian government regarding the mine operation at Amulsar. These failures were also confirmed by the decision of the Administrative Court of Armenia, published on 4 December 2024 after 9 years of litigation; the court found that the officials involved in the environmental impact assessment (EIA) did not have necessary professional background, and therefore they could not be able to assess the EIA documents. There is also an ongoing complaint in the Bern convention (Complaint No. 2020/04: Armenia: The Amulsar gold mine project and its impacts on Emerald Network sites) and the Convention Bureau “reiterated its request for a new Environmental Impact Assessment (EIA) which considers all the species and habitats present in the area. It further asked the authorities to suspend any permits for the exploitation of subsoil until the new EIA has been completed”.
Having considered the above-mentioned, it is very unfortunate to see that the EBRD is still indirectly involved in this project through Ameriabank CJSC. A project, which clearly did not pass proper environmental and social assessment, a project that was also criticized by the Accountability Counsel, and EBRD was called to commit to strengthening its policy and the implementation of that policy, as well as its commitment to remedy, to fulfill its development mandate and ensure communities are left better as a result of its investments. Currently, EBRD is doing the exact opposite of those recommendations.
We would like to highlight that EBRD’s continuous involvement in Amulsar mining significantly affects its reputation. We expect EBRD as a shareholder of Ameriabank CJSC to initiate a risk assessment including, environmental, social, financial, legal and reputational risks of financing Amulsar mining project - publicly disclosing and consulting how it is addressing the situation. In case Ameriabank continues to support the project, we demand the EBRD to suspend its partnership with the bank and adhere to its environmental and social policies and standards, international conventions and the rule of law in our country.
Signatories
"Transparency International Anticorruption Center" NGO
“Ecolur” Informational NGO
“Green Armenia” NGO
“Centre for community mobilization and support” NGO
“Armenian Forests” Environmental NGO
Armenian Environmental Front
Human Rights Research Center
Helsinki Citizens’ Assembly Vanadzor
Journalists’ Club “Asparez” NGO
“Pink” Human Rights Defender NGO
"Protection of Rights without Borders" NGO
September 12, 2025 at 13:51