October 25, 2021

To the Board of Directors of the Asian Infrastructure Investment Bank

In the situation of the ongoing social and political crisis in Belarus, the regime of Alexander Lukashenko, while demonstrating the practices of the occupying government in their own country, continues to use the resources of international inter-governmental financial systems for the purpose of retaining their own power.

After the fraudulent elections of 2020, the illegitimate Belarusian president appointed a government in violation of Belarusian laws and international obligations of the Republic of Belarus, including the International Covenant on Civil and Political Rights (ICCPR). The regime headed by Lukashenko continues to publicly and cynically violate the international obligations of the Republic of Belarus in order to achieve personal goals of the  small elite composed of the Lukashenko family members and their allies. Lukashenko’s illegitimate regime continues to speak on behalf of the people of Belarus in multilateral banks and financial organizations, applying for financing of various infrastructure and commercial projects with ambiguous goals and dubious structures, taking advantage of the broken system of checks and balances and the forced silence of the repressed civil society.

Over the past 12 months, Belarusian civil society has been under unprecedented pressure from the Lukashenko regime. More than 800 internationally recognized political prisoners are detained or imprisoned under unjust judgments. More than 250 associations were terminated by the Belarusian courts on the submission of the illegitimate authorities. Dozens of independent media organisations ceased their work in Belarus after they were labelled as extremist, and their journalists were imprisoned or forced out from Belarus. The Belarusian governmental mass media have stopped all journalist activities and focused on producing mass propaganda materials, inciting ethnic, gender, and religious discord between various groups of the population, the reason for which they were expelled from the European Broadcasting Union (EBU).

In this unfortunate situation, Asian Infrastructure and Investment Bank (AIIB) received an application from the Minister of Health of the Republic of Belarus, Dmitry Pinevich, for the allocation of 116.27 million euros to finance an emergency response project in Belarus, which includes purchasing of medical equipment and awarding consultants involved in the project (Project 000486).

The Association of Belarusian medical workers “Medical Solidarity Fund” (Kyiv, Ukraine), the international association of Belarusian communities “Belarusians Abroad”, the Professional Union of Belarusians in Britain (PUBB) and medical workers of the Ministry of Health and the other NGOs listed below analyzed the project submitted by Minister Pinevich and, taking into account the situation in the Republic of Belarus, concluded the following:

1.  The management of the Ministry of Health, the Ministry of Finance, the National Bank of the Republic of Belarus, appointed to their positions by illegitimate dictator Alexander Lukashenko, have no right, jointly or separately, to represent the Government of the Republic of Belarus as a sovereign borrower of credit funds in relations with multilateral  banks and financial organizations. 

2.  The regime of Alexander Lukashenko, does not and should not have a credit of confidence from multilateral banks and financial organizations to be a party of the international financial agreements in which the Belarusian government acts as a sovereign borrower of funds. Indeed, other multilateral lenders like EBRD have stopped considering all new sovereign projects in Belarus, while EIB stopped all sovereign disbursements altogether. Moreover, under the applicable EU Regulation on sectoral sanctions on Belarus, each EU member state has to “take the necessary action to limit the involvement in Belarus of multilateral development banks of which they are members (…) , including by voting against new loans or other forms of financing” (article 2m). 

3.  The regime of Alexander Lukashenko has repeatedly violated or misused the international instruments to which the Republic of Belarus is a party (including the Belarus-EU Agreement on readmission of migrants (before Belarus withdrew from it on 14 October 2021), the WHO by-laws, the Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87) (as confirmed again by the recent report of International Labour Organisation (ILO)), the Constitution of Interpol) and is unable to provide transparency of the procedures stipulated in the financing agreements, in particular the use of credit funds, and credibility of reporting, even if such credit funds were provided by AIIB to Belarus for the purchase of medical equipment.

4.  The Ministry of Health represented by the Minister Dmitry Pinevich who has been systematically and deliberately providing false information about the state of the healthcare system, the number of people who have become ill and died from COVID-19 to their international partners and their own citizens, cannot ensure the transparency of procedures and credibility of their reporting during the implementation of the project submitted to AIIB.

5.  The Ministry of Health under Minister Dmitry Pinevich and the Republican Scientific and Practical Center for Medical Technologies, Informatization, Management and Economics of Health Care headed by director Dmitry Ruzanov cannot ensure transparent use of AIIB credit funds, since purchasing of medical equipment and services of unnamed consultants does not guarantee that project’s goal will be achieved – namely, that the people of Belarus will be supported in the COVID-19 health crisis and the sustainable development of the public health sector in the country will occur.

The above bodies are basing these conclusions on evidence-based argumentation and urge the AIIB Board of Directors to refuse a loan to Belarus for financing an emergency response project until the Belarusian side provides the evidence that the social political situation in Belarus has improved, and namely:

1.  Alexander Lukashenko has resigned;

2.  All political prisoners are released unconditionally;

3.  Transparent democratic elections of the president and parliament are held, and the new legitimate government is appointed;

4.  Public control over the activities of state administration bodies is in place in the form of the civil initiatives and journalists of independent media presence in public processes and their unimpeded access to public documentation.

  • Belarusian Medical Solidarity Foundation
  • International association of Belarusian communities “Belarusians Abroad”
  • Professional Union of Belarusians in Britain (PUBB)
  • Medical workers of the Ministry of Health of Belarus 
  • Just Finance International
  • Both ENDS
  • Crude Accountability
  • CEE Bankwatch Network 
  • CLEAN (Coastal Livelihood and Environmental Action Network)
  • Jamaa Resource Initiatives
  • NGO Forum on ADB
  • ReCommon
  • Recourse
  • Rivers without Boundaries
  • Verein für sozial-ökologischen Wandel
  • Peace Point Development Foundation
  • Latinoamérica Sustentable