public criticism has been muted. Donors should seek ways to leverage their funding and press Bangladesh to agree to meet human rights benchmarks on education for Rohingya children, including access to formal, accredited education. The World Bank has recognized the need for multi-annual, concessional funding for lowincome countries hosting refugees, and raised $2 billion in dedicated funding for this purpose in 2018.28 It has required some governments to have an action plan to meet refugees’ needs in order to access this “sub-window” of financing: the bank delayed funding for an employment program in Ethiopia, for instance, until the government fulfils its commitment to allow some refugees to move freely and legally work outside of camps.?8 The Bank has also refused to finance education systems that violate human rights, including by withholding a $300 million loan to Tanzania until schools stop barring and expelling pregnant girls.287 In Lebanon, where the bank is providing a $100 million credit and $12, in trust fund financing over five years to improve education for Syrian refugees as well as vulnerable Lebanese children, it has linked disbursals to meeting annual benchmarks such as increases in enrollment and better data collection and transparency.288 The World Bank’s new lending globally is guided by its 2016 Environmental and Social Framework, which went into effect on October 1, 2018. This framework states that “inclusion” is “critical for all of the World Bank’s development interventions,” and “encompasses policies to promote equality and non-discrimination by improving the access of all people, including the poor and disadvantaged, to services and benefits such 285 Sarah Charles, Cindy Huang, Lauren Post, Kate Geogh, “Five Ways to Improve the World Bank Funding for Refugees and Hosts in Low-Income Countries and Why These Dedicated Resources Matter More than Ever,” Center for Global Development, November 18, 2018, https://www.cgdev.org/publication/five-ways-improve-world-bank-funding-refugees-and-hosts-low- income-countries-and-why (accessed July 23, 2019). 286 Id. 287 “Rights Groups Press Tanzania to Drop Pregnant Students Ban,” Human Rights Watch, June 18, 2018, https://www.hrw.org/news/2019/06/18/rights-groups-press-tanzania-drop-pregnant-students-ban; “World Bank scraps $300m education loan to Tanzania over ban on pregnant schoolgirls,” Theirworld, November 15, 2018, https://theirworld.org/news/world-bank-scraps-300m-education-loan-to-tanzania-over-ban-on-pregnant-schoolgirls (accessed September 15, 2019). 288 World Bank, “Lebanon - Reaching All Children with Education (RACE 2) Program for Results Project,” Report No. 108014, September 2, 2016, http://documents.worldbank.org/curated/en/980641475200856910/pdf/Lebaon-RACE2-PforR-Board- Package-PAD-WB-9-5-16-09072016.pdf (accessed December 10, 2018). 71 HUMAN RIGHTS WATCH | DECEMBER 2019