Responsible Business Conduct for Sustainable Infrastructure in Kazakhstan, Mongolia and Uzbekistan

4. Uzbekistan

Abstract

This chapter analyses how Uzbekistan is encouraging responsible business conduct (RBC) for sustainable infrastructure. It considers the country’s legal and policy framework in a range of policy areas as well as the state’s economic role and commercial activities. It highlights progress and challenges and identifies opportunities for how Uzbekistan can strengthen the integration of RBC in infrastructure development and operations.

4.1. Overview of infrastructure development in Uzbekistan

With 36 million inhabitants, Uzbekistan is the country with the largest population in Central Asia. It is one of two double-landlocked countries in the world, bordering only countries that themselves have no direct maritime border. The country has attained a status of high human development, ranked 106 out of 193 in 2022 (UNDP, 2024[1]). Uzbekistan has consistently reported high growth rates over the past decade, between 4.4% and 7.4% (with 2% in 2020 due to the COVID-19 pandemic) (World Bank, 2024[2]). Its GNI per capita of USD 2 700 in 2023 places it in the category of lower-middle-income countries (World Bank, 2024[3]).

Infrastructure investments feature prominently in Uzbekistan’s development policies. The Uzbekistan 2030 strategy sets out the country’s ambition to expand its infrastructure to respond to citizens’ needs and foster economic growth (Republic of Uzbekistan, 2023[4]). This includes objectives on transport infrastructure, power generation, both thermal and renewable, and gas and mineral extraction. The strategy also aims to enhance the industrial infrastructure to transform gas, minerals, cotton, and other textile products in the country. Attracting investments plays a critical role in this regard. An objective under the strategy is to develop “500 strategically important technological and infrastructure projects with a total value of USD 150 billion”. These longer-term infrastructure objectives build on similar priorities under the medium-term New Uzbekistan Development Strategy 2022-2026 (Government of Uzbekistan, 2022[5]).

Expanding the transport network and intensifying usage are key objectives for Uzbekistan. Uzbekistan has a sizeable road network, although coverage is lower in southern and western regions (around 5.8 million people do not have all-season road access) and challenges of maintenance and road quality exist (ADB, 2022[6]; Ministry of Transport, 2023[7]). The rail network has been expanded over the past years, including through a first high-speed line (World Bank, 2019[8]). Uzbekistan ranks 89^th in the 2023 Logistics Performance Index in terms of infrastructure (World Bank, 2023[9]). Gaps in infrastructure, equipment, and quality lead to Uzbekistan having the highest transportation costs in Central Asia (World Bank, 2022[10]). To reduce the cost of trade and travel time, enhance opportunities for cross-border trade, and seize its role as transit country in trade flows from and to China, Uzbekistan foresees significant investments in its transportation infrastructure. The government projects the construction of 5 500 km of paved roads, rehabilitation of more than 50 000 km of roads, expansion of high-speed railways, and increased electrification and modernisation of several airports (Republic of Uzbekistan, 2023[4]).

Uzbekistan invests in both renewable and thermal energy production while enhancing energy efficiency. Natural gas provides 85% of both total energy supply and electricity supply sectors (IEA, 2022[11]). Legacy infrastructure, with almost 40% of available generation capacity past service life, requires renewal and upkeep to drive down efficiency losses (IEA, 2022[11]). While CO2 intensity fell by nearly 75% between 2000 and 2020, current levels remain 77% above the world average (OECD, 2023[12]). Under its Uzbekistan 2030 strategy, the country aims to double the efficiency of the energy sector by 2030, modernise gas-fired power plants, and install renewable energy capacity to bring the share of renewables in total energy consumption to 40% from less than 2% in 2020 (Republic of Uzbekistan, 2023[4]; IEA, 2022[11]). Uzbekistan is significantly stepping up the capacity of wind and solar power generation. To manage the expansion of renewable energy, investments in the transmission network and storage will be essential (OECD/ADB, forthcoming[13]). While plans to construct nuclear power plants exist, their realisation is uncertain (IEA, 2022[11]).

Mining and natural resource extraction occupy a significant part of Uzbekistan’s economy and the government aims to step up exploration, production, and transformation. While Uzbekistan’s economy is relatively diversified, extractives such as gold (with 30% of exports in 2022, (OEC, n.d.[14])), copper and silver are key export products, as is natural gas (6%). These sectors have driven economic growth from 2010-2019 (World Bank, 2022[10]). Uzbekistan is also one of the world’s largest uranium producers. Under Vision 2030, Uzbekistan would like to further increase production of all these raw materials by up to 3 times by 2030, as well as processing capacity and industrial activities such as in chemical and automotive industries (Republic of Uzbekistan, 2023[4]).

4.2. Opportunities for promoting RBC in infrastructure development in Uzbekistan

RBC principles and standards set out that all businesses – regardless of their legal status, size, ownership structure or sector – address adverse impacts of their operations on people, planet and society, and contribute to sustainable development where they operate, including throughout their investments and supply chains. Due to their size and nature, infrastructure development and operations can affect the human rights of local communities such as their land rights and livelihoods. They can impact the rights of workers, notably their health and safety, and create significant harm to the environment and contribute to climate change. The large financial amounts involved can also give rise to corruption. As governments seek greater levels of private sector involvement in financing, delivering, operating, maintaining, and decommissioning infrastructure, promoting and enabling a positive business contribution while minimising adverse impacts on people, planet, society is critical (see The role of responsible business conduct in enabling sustainable infrastructure). For more detailed information on Uzbekistan, please consult the “Roadmap on Sustainable Investment Policy Uzbekistan” report, notably, the chapters on responsible business conduct and green investment (OECD/ADB, forthcoming[13]).

4.2.1. Consolidating legal and policy frameworks relevant for RBC and applicable to infrastructure development

Overarching framework for responsible business conduct

Responsible business conduct (RBC) is increasingly high on Uzbekistan’s policy agenda. In top-level policy documents such as the Uzbekistan 2030 strategy, the government has committed to addressing some of the major adverse impacts of business operations, notably, related to pressure on natural resources, climate change, and corruption (Republic of Uzbekistan, 2023[4]). Attention to RBC is growing. There is recognition at the highest political level that RBC plays a role in attracting investments (President of the Republic of Uzbekistan, 2024[15]). This has led to the creation of a working group on RBC in the Foreign Investors Council, which includes companies from infrastructure sectors such as renewable energies. Moreover, the government is promoting environmental, social, and governance (ESG) risk management, specifically in state-owned enterprises (see below) (Government of Uzbekistan, 2023[16]). It is also developing a new strategy for small and medium-sized enterprises (SMEs) development. A draft shared with the OECD includes a goal to promote RBC through national standards and support to SMEs.

The commitment to adopt a National Action Plan on Business and Human Rights (NAP BHR) presents an opportunity to promote RBC in infrastructure (Government of Uzbekistan, 2023[17]). The government has already conducted consultations and elaborated actions that could be included in the NAP BHR but not all relevant stakeholders were involved early on. The finalisation and implementation of the action plan is a major opportunity to involve ministries overseeing infrastructure investments (notably investments, finance, energy, and transport) to co-ordinate their expectations of the private sector and bring together international and local infrastructure companies, trade unions, and civil society organisations to discuss how to best prevent and mitigate adverse impacts. The government indicates that work in this direction is already underway.

Companies’ awareness of RBC in Uzbekistan is growing. With regard to infrastructure, this is much due to state-owned companies’ attention to ESG. Commercial enterprises with international business dealings are also increasingly aware of their business partners’ expectations. Chambers of commerce and international partners organise events and raise awareness of RBC. However, few of the 21 participants of the UN Global Compact are connected to core infrastructure-related sectors (United Nations Global Compact, n.d.[18]). Different government institutions such as the National Centre for Human Rights are raising awareness, albeit not yet co‑ordinated or spearheaded by a lead institution. Financing by development partners focuses attention on high environmental and social standards in infrastructure (more than USD 350 million over 2021 and 2022 for the energy sector and more than USD 80 million for transport (OECD, 2024[19])) and promotes RBC generally as well as in specific sectors such as textile1 and mining. The government made a specific pledge to raise businesses’ awareness of the UN Guiding Principles on Business and Human Rights (Government of Uzbekistan, 2023[17]). It also sees this as an opportunity to inform businesses about the benefits of RBC (OECD/ADB, forthcoming[13]).

Human rights

Respect for land rights can be a concern for infrastructure development. Legislation from 2022 significantly strengthened the protection of landowners and rules for compensation (Republic of Uzbekistan, 2022[20]; Special Rapporteur on the right to adequate housing, 2024[21]). However, security of tenure and compensation remain challenges in practice (World Bank, 2022[10]) (Special Rapporteur on the right to adequate housing, 2024[21]). This has led to concerns especially in the context of urban development projects for the benefit of private investors, with reports of inadequate protection against or compensation for expropriations (University of Ulster Centre for Public Administration, 2024[22]) (European External Action Service, 2024[23]). A recent amendment to the Housing Code law could be a welcome step to strengthen the protection of landowners (Kun.uz, 2024[24]).

Regional and local dynamics are a relevant consideration for infrastructure investments in Uzbekistan. Numerous investments take place in the Republic of Karakalpakstan, an autonomous region of Uzbekistan. The government indicated that projects valued at around USD 9.5 billion are underway (President of Uzbekistan, 2024[25]). This includes substantial investments in renewable energies: the government foresees the installation of wind farms with a capacity of 10.3 GW by 2030 and part of the supply chain for turbines has already been installed in the region itself. The region witnessed tensions in 2022 (OHCHR, 2022[26]). Challenges in local consultation on infrastructure have been flagged for a waste management project (CEE Bankwatch Network, 2023[27]). At infrastructure project-level, efforts to engage both local authorities and local communities in preparation and implementation is important. An enabling environment for meaningful stakeholder engagement can help further promote investment in the region.

Pollution remains an issue. For the city of Tashkent alone, an estimated 3 000 persons die prematurely every year from particle pollution. This is caused, in part, by industry, commercial heating, transport, and dust from activities around the city though measures to reduce emissions such as electric buses are being introduced (World Bank, 2024[28]). Ensuring that pollution fees and taxes designed in a way they incentivise businesses to invest in cleaner technologies (rather than accept the payment) could be important contributions to a response, as could be automated monitoring (World Bank, 2024[28]). In this regard, the government indicates it is currently discussing with the business community a project on payments differentiated by the degree of pollution.

A requirement to assess social impacts could strengthen infrastructure project development. Contrary to projects financed by international financial institutions, there are no similar requirements in Uzbek legislation to assess environmental or human rights impacts on people affected by projects. While consultation of local populations is mandatory in Uzbekistan, this is not always carried out in practice (see below) and cannot replace a comprehensive assessment and subsequent plan for addressing impacts. Uzbekistan’s experience with the Sustainable Asset Valuation of a road project serves as illustration that the early consideration of social impacts can enhance infrastructure design to improve quality and reduce adverse impacts (IISD, 2023[29]).

Labour rights

The legal framework for labour rights in Uzbekistan has improved but application in practice requires greater attention. Uzbekistan is party to all 10 fundamental International Labour Organization (ILO) Conventions. Uzbekistan has acceded to several other ILO Conventions in recent years, including the Safety and Health in Construction Convention (2022). A new Labour Code has strengthened alignment with international labour rights (Republic of Uzbekistan, 2023[30]). However, labour inspections lack resources. The ability to conduct unannounced inspections was flagged as an important concern, although Uzbekistan is a party to the related ILO Convention No. 81 (UN Committee on Economic, Social and Cultural Rights, 2022[31]; ILO, 2025[32]). It will be important to monitor if a recent change to the system of public inspections – that allows subsequent rather than prior notification of inspections in some cases – will strengthen the effectiveness of labour inspections.

Occupational health and safety are important concerns, notably in the construction sector. A survey has highlighted a range of risks, notably exposure to dust and smoke, and carrying heavy goods without special equipment (ILO/Ministry of Employment and Labor Relations, 2023[33]). Forty per cent of construction workers surveyed indicated they felt their health at work was at risk. Informality is frequent in the construction sector (58% of persons surveyed) and increases risks for health and safety. Acknowledging the challenges, Uzbekistan ratified ILO Convention No. 155 on Occupational Safety and Health in late 2024 and aims to strengthen application of labour standards.

Uzbekistan has made important steps toward eradicating systemic forced and child labour, which had been major concerns in cotton farming (Cotton Campaign, n.d.[34]). This is due to very significant efforts to revise the legal framework and invest in prevention and controls (ILO, 2022[35]). Continuing these efforts will be important (ILO, 2025[32]). Some incidents of child labour persist, including in the construction sector (UN Committee on the Rights of the Child, 2022[36]; ILO, 2025[32]) (US Department of Labour, 2023[37]). In a survey, 1.5% of construction workers indicated being subject to forced labour (ILO/Ministry of Employment and Labor Relations, 2023[33]).

Despite significant progress, gender equality remains an important challenge. Uzbekistan enhanced its legal framework to reduce discrimination (World Bank, 2024[38]). A government strategy to promote gender equality also focuses on the economic sphere (Government of Uzbekistan, 2021[39]). Infrastructure sectors have the lowest shares of women employees (between 27% for mining and 6% in construction). At 39%, the gender pay gap in Uzbekistan is substantially higher than in Kazakhstan and Mongolia (each at 20%) (World Bank, 2024[40]; National Statistics Office of Mongolia, 2024[41]). Work is ongoing to raise awareness of employers and promote compliance with equal pay rules under national legislation.

The 2020 Law on Trade Unions strengthened the role of unions, while freedom of association could be further enhanced (Republic of Uzbekistan, 2020[42]). The law foresees consultation on legislation, and unions actively participate in dialogue with social partners (FTUU, 2024[43]). They also have the right to independently inspect workplaces and help resolve worker complaints, e.g. recovering wage payments (FTUU, 2024[43]). Complaints about wage payments also led to worker movements in infrastructure-related companies (Kun.uz, 2024[44]). The right to strike is not explicitly recognised in legislation (ILO, 2025[32]). Moreover, according to legislation, founding a union requires at least 3 000 workers. As this threshold is too high for many initiatives to meet, a downward revision is currently under consideration. Operating trade unions independently and outside the Federation of Trade Unions of Uzbekistan is reportedly a challenge, leading international bodies to recommend Uzbekistan to facilitate the freedom of trade unions and their independent activities (UN Human Rights Council, 2023[45]; ILO, 2025[32]).

Environment

Energy, mining, construction, and industry contribute to severe environmental challenges. Uzbekistan suffers extreme water stress that is expected to intensify due to climate change, and intensive water usage and polluting industrial activity contribute to water scarcity (Ministry of Ecology, Environmental Protection and Climate Change, 2023[46]). Pollution levels are high, with consequences for human health, and industrial waste management requires improvement (Ministry of Ecology, Environmental Protection and Climate Change, 2023[46]). Industrial activity is very energy-intensive, and based on 2019 data, Uzbekistan is the world’s fifth most greenhouse gas-intensive economy (World Bank, 2022[10]). Land degradation has a major cost for the economy (The World Bank and the Ministry of Economic Development and Poverty of Uzbekistan, 2022[47]) and while mostly linked to farming, mining also contributes to the phenomenon.

Top-level policies are prioritising reducing the environmental impacts of business activities. Strategy Uzbekistan 2030 reaffirms the direction taken by the Green Economy Transition Strategy 2030, the Updated Nationally Determined Contribution, and the Concept on Environmental Protection until 2030. Key objectives include reducing greenhouse gas emissions; enhancing renewable energies; increasing industrial energy efficiency; reducing pollution; improving water usage; and addressing land degradation (Republic of Uzbekistan, 2023[4]; 2019[48]; 2019[49]; 2021[50]). The 2022 Programme on the Transition to a Green Economy specifically foresees the integration of “green” and ESG standards in investment policies and projects (Government of Uzbekistan, 2022[51]). However, the IEA energy policy review noted that subsidised tariffs act as a disincentive for greater energy efficiency and subsidies for natural gas in electricity generation discourage the use of renewable energies (IEA, 2022[11]; OECD/ADB, forthcoming[13]).

The framework for environmental impact assessments (EIAs) could be further enhanced to manage the risks of infrastructure investments. EIAs are governed by a specific law that sets out the process and defines risk categories so that infrastructure projects are typically subject to closer scrutiny (Republic of Uzbekistan, 2000[52]). Clarity on requirements and process, attention to climate impacts, and more opportunities for public engagement could enhance the framework (World Bank, 2023[53]). It would also be important to ensure that all high-risk projects are classified as Category I and sufficient time is available for a review (OECD/ADB, forthcoming[13]). In the context of connectivity infrastructure, transboundary impact assessments would also be highly relevant. However, Uzbekistan is not yet a party to the Espoo Convention Environmental Impact Assessment in a Transboundary Context (unlike Kazakhstan). Strategic environmental assessments of large public development programmes, which are not yet part of Uzbekistan’s framework, could help identify potential adverse impacts of subsequent infrastructure investments (OECD/ADB, forthcoming[13]). A study for a road project has demonstrated the potential benefits of early design and impact assessments through digital twins (Asian Development Bank, 2023[54]).

The government is taking action to reinforce legal standards in practice. It is reported that standards are frequently ignored, due to low awareness of companies, monitoring that is not fully effective, and a fine structure that appears not to be sufficiently dissuasive (World Bank, 2023[53]; Smutny, 2021[55]; Republic of Uzbekistan, 2023[56]). In response, the government is taking a range of actions to strengthen the promotion, monitoring, and enforcement of businesses’ environmental compliance (for these categories, see the OECD Recommendation on Environmental Compliance Assurance [ (OECD, 2023[57])) (see Box 4.1). Further efforts are ongoing. For example, Uzbekistan is currently strengthening its institutional capacity on climate monitoring, reporting, and verification (Ministry of Economy and Finance of Uzbekistan, 2024[58]).

Box 4.1. Strengthening compliance with environmental standards

Explicitly recognising shortcomings in compliance with environmental standards, the government of Uzbekistan has introduced several reforms over the past years:

• Compliance promotion: The government provides support such as a dedicated credit line to companies so they can upgrade to better technologies for emission management and water usage. To enhance transparency of environmental impact assessments, an online registry contains public conclusions, including for high-risk Category I projects2. The government also publishes its ratings of EIA service providers3. To gain a competitive advantage, companies can obtain “green certifications” after a voluntary verification that production processes respect environmental standards.

• Compliance monitoring: High- and medium-risk facilities must install automated monitoring equipment. High-risk facilities must undergo annual verification under the 2021 Law on Environmental Audits. The role of the Inspectorate for Control in the Field of Ecology and Environmental Protection was strengthened, with a clear acknowledgement of its independence vis-à-vis other public services. Inspections are not subject to prior approval. Volunteers can register and receive training to identify violations of environmental standards; to incentivise their work, they can receive a share of the fine imposed on a company.

• Compliance enforcement: Fines for violations were significantly increased. Companies without a positive EIA can be deprived of access to public funding. Crimes against the environment were reclassified in a more serious category and a dedicated deputy prosecutor general’s office for environmental crimes was created

Source: Republic of Uzbekistan: (2021[59]) Law on Environmental Audit, https://lex.uz/en/docs/5331135; (2023[56]); Decree on measures to transform the sphere of ecology and environmental protection and the organization of the activities of the authorized state body, https://lex.uz/ru/docs/6479185; (2023[4]) Decree No 737 by the Cabinet on improving the system of environmental monitoring in the Republic of Uzbekistan, https://lex.uz/docs/6600404; (2023[60]) Decree on Measures for High-quality and Timely Implementation of the Strategy "Uzbekistan - 2030", https://lex.uz/uz/docs/6600415.

Government of Uzbekistan: (2019[61]) Decree No 737 on improving the system of environmental monitoring in the Republic of Uzbekistan, https://lex.uz/docs/4502814; (2024[62]) Decree No 101 on the Community Environmental Controller Regulation, https://lex.uz/uz/docs/-6815438; (2021[63]) Decree no. 541 on Further Improvement of the Mechanism for Assessing the Impact on the Environment, https://lex.uz/docs/5370061.

Ministry of Ecology, Environmental Protection and Climate Change (2023[46]), National State of the Environment Report: Uzbekistan, https://unece.org/sites/default/files/2024-02/uzbekistan-state-of-the-environment-en.pdf.

A new law aims to enhance energy efficiency of industrial activities. Energy audits, mandatory certification on energy management under ISO 50001 for state-owned enterprises, and building standards were some measures to promote energy efficiency, however, with limited success (OECD/ADB, forthcoming[13]). The government identified important gaps, stating that “the country does not have an effective system for monitoring energy consumption, energy consumption standards and conducting energy audits” (Ministry of Energy, 2024[64]). The 2024 Law on Energy Saving, Rational Use, and Energy Efficiency targets, in particular, high-energy consumers, who are included in an energy register and must optimise their energy use, undergo mandatory energy audits, and train energy managers (Republic of Uzbekistan, 2024[65]). The law outlines measures for specific sectors, including industrial units and construction.

Investments in renewable energy infrastructure require managing impacts on biodiversity. Impact assessments of multilateral development banks highlighted significant effects that wind farms and solar power plants can have on birds, including threatened species (e.g. (ADB, 2023[66])). While such impacts can be prevented and mitigated by adjusting location, design, and operations of turbines, civil society organisations have filed a complaint against a large wind farm project, alleging that the site location is too close to key areas of bird protection ( (EBRD, 2024[67])). In the case of another wind farm, the government had assigned a land plot that overlapped with a national nature park and an international bird area, putting the onus on project developers to identify a solution within this area (ADB, 2023[66]) (CEE BankWatch Network, 2023[68]).

Uzbekistan is taking action to better manage environmental risks of extractive industries. Particular concerns are water pollution and land degradation, affecting biodiversity, agriculture, and access to safe water (Chuluunbat, 2025[69]). The revised Law on Subsoil requires a public environmental impact assessment and obliges operators to protect the environment and re-establish previous conditions with a requirement to provide financial guarantees (Republic of Uzbekistan, 2024[70]). In 2023, the government launched a dedicated programme to manage the environmental impacts of mining by preventing pollution. This improved waste management, enhanced the alignment of operations with international standards, and allowed SOEs to have their energy and environmental management certified (Ministry of Mining and Geology, 2024[71]). To protect the Syr Darya River, Uzbekistan has imposed an indefinite moratorium on mining of non-metallic minerals (Daryo, 2024[72]). International partners are providing support, for instance, to enhance waste and pollution management of the mining industry and address impacts of legacy uranium mining sites (UNECE, 2024[73]; Usov, 2023[74]). Uzbekistan recognised artisanal mining in its legal framework in 2019, subject to licensing, and increased sanctions for illegal mining in 2023 (Kuz.uz, 2024[75]; Times of Central Asia, 2024[76]). Moving artisanal mining out of illegality can help reduce conflicts around land usage and improve mining practices to prevent workplace accidents and environmental damage.

Corruption and business integrity

A range of legal and institutional measures support the fight against corruption (OECD, 2024[77]; OECD, 2024[78]). These include a law on combating corruption in 2017 and related clauses on the prevention of corruption in laws on procurement and public-private partnerships; enhanced transparency and digitisation in procurement; the creation of a dedicated anti-corruption agency4 in 2020; and the development of an Anti-Corruption Business Charter in 2021 (Anti-Corruption Agency, 2023[79]; Republic of Uzbekistan, 2017[80]; Business Ombudsman, 2021[81]). Particularly important for infrastructure, the government is also strengthening the corporate governance of state-owned enterprises to improve their corruption risk management (IMF, 2024[82]). Survey respondents see progress in the fight in corruption (Transparency International, 2024[83]; World Justice Project, n.d.[84]; Business Ombudsman, 2021[81]).

Perceptions of corruption persists, and cases and allegations of corruption affect infrastructure sectors. In 2023, 8% of surveyed businesses encountered corruption at all times and 34% sometimes when dealing with authorities (Anti-Corruption Agency, 2023[79]). In infrastructure sectors, convictions in cases of corruption relate, for instance, to real-estate construction and a dam collapse (Gogidze, 2024[85]). In early 2023, the government pushed for investigations of corruption in the energy sector (Daryo.uz, 2023[86]). Information on allegations of corruption in the hydrocarbon energy sector has been submitted to the Foreign Affairs Committee of the Parliament of the United Kingdom (Lasslett, 2023[87]) and concerns raised around solar energy projects (Bekieva, 2024[88]). To fight corruption, the government has started to digitize subcontracting, for instance, in road and bridge constructions in July 2024 (Presidency of Uzbekistan, 2024[89]). Specifically for projects financed by international financial institutions, the Anti-Corruption Agency has been tasked with supervising the transparent and accountable use of funds by verifying online information of ministries and conducting site monitoring, including in collaboration with local initiative groups.

Remaining gaps in the framework can increase corruptions risks for infrastructure investments. Uzbekistan does not participate in the Extractive Industries Transparency Initiative (EITI), which could significantly enhance transparency around key sectors for the economy. In public procurement, the possibility of fast-tracking government’s investment programme projects raises corruptions risks (World Bank, 2023[53]). The corporate governance framework for private enterprises has gaps on anti-corruption and monitoring of compliance needs to improve (OECD, 2024[78]). In SOEs, the rules on appointment of board and company leadership were only recently improved to promote merit-based selection (OECD, 2024[78]). Proximity between persons working in public authorities and private enterprises has been highlighted as a factor in corruption cases (Gogidze, 2024[85]). Importantly, Uzbekistan introduced legislation on conflict of interest in mid-2024 and its application through guidelines and training will be critical (OECD, 2024[77]). As an example of preventive action in the energy sector, the Anti-Corruption Agency engaged with a deputy minister to cease his activities in two private companies in the sector (OECD, 2024[78]).

4.2.2. Encouraging RBC in infrastructure development through finance and investment

Sustainable finance and non-financial disclosure can set important incentives for companies in infrastructure sectors to strengthen their observance of RBC-related standards. Through investment promotion and facilitation, the government can help attract infrastructure investors with greater attention to RBC.

Sustainable finance and non-financial disclosure

Sustainable finance has risen on the agenda in Uzbekistan. The state and state-owned banks issued a series of sustainability-related thematic bonds (e.g. Sustainable Development Goal (SDG) bonds, green bonds) on foreign stock exchanges and joint listings starting in 2019. The government developed and adopted a green taxonomy (OECD, 2023[90]). In 2024, the Mortgage Refinancing Company issued Uzbekistan's first locally-listed green bond on the Tashkent Republican Stock Exchange and the Uzbekistan Direct Investment Fund supported the issuance of a social bond, both with support from the Astana International Finance Centre (AIFC, 2024[91]; UzDIF, 2024[92]). In the banking sector, state-owned Sanoat Qurilish Bank (SQB) and Joint-Stock Commercial Bank (JSCB) Agrobank have issued green bonds. This dynamic supports domestic financing of sustainable infrastructure investments. Among the largest banks of Uzbekistan, SQB is a frontrunner and publishes its ESG risk management policies5 while other banks are not yet publishing information on sustainability, RBC or ESG risk management on their investor websites.

Mandatory non-financial disclosure was recently introduced for SOEs. SOEs need to provide annual ESG reporting, with related guidance clarifying that this encompasses risks that businesses create for people, planet and society (Republic of Uzbekistan, 2024[93]) (UzSAMA, 2024[94]). Sustainability reporting and disclosure is good practice, as set out in the OECD Guidelines on Corporate Governance of State-Owned Enterprises [ (OECD, 2024[95]). Under the guidance in Uzbekistan, sample indicators relate to climate emissions, waste, pollution, water consumption, work-related injuries, and attraction of sustainable investments. Considering the major role of SOEs in Uzbekistan in infrastructure sectors, implementing this requirement could be an important enabler for better practices. In contrast, there are no RBC-related reporting requirements for private enterprises and voluntary reporting on non-financial issues is weak (EBRD, 2020[96]).

Investment promotion and facilitation

There is space to increase considerations of responsible business conduct and sustainability in infrastructure investment promotion. The Law on Investment (Republic of Uzbekistan, 2019[97]) is the key framework for signing deals with foreign investors, for instance, investments in renewable energies. In an ongoing revision of the law, the government aims to strengthen references to sustainability to underline that investments should contribute to Uzbekistan’s sustainable development6. This includes promotion of RBC as one of basic principles of working with investors. It will be important to translate this objective into Uzbekistan’s practice of investment promotion. The government’s current investment guide is silent on sustainability or responsible business practices (Ministry of Investments and Foreign Trade of the Republic of Uzbekistan, 2022[98]). The government could notably engage with potential investors on the extent to which they have included RBC practices in their business operations and their efforts to mitigate adverse efforts on local communities and the environment. Similarly, the government could strengthen attention to RBC in infrastructure development in special economic zones, building on its current practice under the Law on Special Economic Zones (SEZs) to engage with businesses on measures to reduce pollution (Republic of Uzbekistan, 2020[99]). Ongoing reflections on legislation that would allow the creation of “green zones” and “eco-industrial zones” could support such a dynamic.

Some bilateral trade and investment agreements include clauses related to RBC. The United States leads policy dialogue with Uzbekistan on worker rights under its Central Asia Trade and Investment Framework (Office of the United States Trade Representative, 2024[100]). The Enhanced Partnership and Cooperation Agreement with the EU, currently under negotiation, will likely contain dedicated references to responsible business conduct (European Commission, n.d.[101]; Dunyo Information Agency, 2024[102]). Like Mongolia, Uzbekistan participates in the EU’s Generalised Scheme of Preferences Plus (GSP+) for preferential access for its exports and is subject to regular monitoring of RBC-related obligations (European Commission, 2023[103]). In 2024, Uzbekistan and the EU also signed a memorandum of understanding on critical raw materials, where both parties agree, among other things, to co‑operate in the “sustainable and responsible production and sourcing of critical raw materials” (Delegation of the EU to Uzbekistan, 2024[104])

4.2.3. Exemplifying RBC in infrastructure development via the state’s economic role and commercial activities

The state plays a major role in infrastructure development and operations. Frameworks for public procurement, public-private partnerships and corporate governance of state-owned enterprises can therefore incentivise and support responsible business conduct for sustainable infrastructure.

Public procurement

Uzbekistan can build on its efforts in the area of green public procurement to encourage RBC of infrastructure suppliers. The Law on Public Procurement (Republic of Uzbekistan, 2021[105]) allows authorities to apply environmental considerations in their procurement. However, these are voluntary only and often not applied in practice (Nemec et al., 2023[106]). The Ministry of Economy and Finance takes action to expand green procurement through training and has issued guidance on green procurement for food, textiles, paint, and cleaning material, whose application is pilot-tested by a number of institutions (MEF, 2024[107]). Building on this experience, the government could explore expanding green procurement to institutions and sectors more directly related to infrastructure investments and operation. For example, OECD members like the Netherlands focus on CO2 emissions in infrastructure procurement (OECD, 2024[108]).

Greater consideration for sustainability provides an opportunity to introduce RBC considerations in infrastructure-related procurement. The government has recently introduced a principle of sustainability in the law on public procurement (Republic of Uzbekistan, 2024[109]). This could help draw attention to RBC-related considerations such as worker rights and supply chain due diligence in public procurement for infrastructure projects. Regarding the long-term environmental footprint of infrastructure, it should be noted that the law already contained a requirement to consider the full cost of the operating cycle. Applying this requirement would be highly relevant for infrastructure-related procurement as it expands consideration beyond the initial price of installation to subsequent costs of energy, resource consumption and possible repairs (OECD, 2020[110]).

Public-private partnerships

PPPs are highly relevant for infrastructure development in Uzbekistan. Specific PPP legislation is mostly applied to infrastructure projects in education, health, and water (Republic of Uzbekistan, 2019[111]), and, of recent, to two very large-scale road projects under preparation, with potential for further projects (ADB, 2024[112]). For other projects, the government has applied the Law on Investments, in particular, for energy sector projects. Law on PPPs contains no particular references to sustainability or responsible business conduct. However, a regulation on the identification and selection of PPPs specifies that large-scale projects (above USD 10 million) need to undertake a feasibility study that includes an analysis of social, economic, and environmental impacts, and conclusion on alignment with international environmental, social and governance (ESG) standards (Government of Uzbekistan, 2024[113]). Interviews indicate that the impact analysis under the regulation is not yet sufficiently extensive to shape the subsequent design of PPPs. A more in-depth consideration for adverse impacts would need greater capacity of public authorities (Schloemer, 2024[114]). The regulation also requires public discussions before approval of the project concept. This is an important element for a clear, predictable, and legitimate institutional framework for PPPs as set out in the OECD Recommendation on the Principles for Public Governance of Public-Private Partnerships (OECD, 2012[115]). As the government monitors PPPs through key performance indicators (KPIs), including the management of adverse impacts in KPIs could be a way to maintain attention to important risks.

State-owned enterprises

To strengthen the performance of state-owned enterprises (SOEs), their observance of RBC has become an important policy objective. SOEs are major players in infrastructure development and operation in Uzbekistan, holding central positions in the energy, mining, rail, and airway sectors. They are also significant actors in the financial market and can influence infrastructure investments through their lending. Building on earlier work to promote anti-corruption, the government is promoting ESG risk management in SOEs through policy, support, and corporate governance requirements (see Box 4.2).

Some SOEs in infrastructure sectors already lead by example. In the energy sector, Uzbekneftegaz issues sustainability reports, using the Global Reporting Initiative standards (Uzbekneftegaz, 2023[120]). In contrast, in the transport sector, the SOE Uzbekistan Railways provides no specific information related to RBC on its website. In the mining sector, two major SOEs, Navoi Mining and Metallurgical Company and Almalyk Mining and Metallurgical Complex (AMMC), have put in place sustainability policies and more specific policies on human rights, diversity and inclusion, and environmental protection. They also issue sustainability reports (Navoi Mining and Metallurgical Company, 2023[121]). Mining companies were certified on good environmental and labour management practices (Ministry of Geology Industry and Mining, 2024[122]). AMMC has put in place a supplier code of conduct that sets out RBC expectations, including an expectation to uphold the code of conduct also in relation to sub-contractors and an encouragement to collaborate with AMMC on better environmental management (Almalyk MMC, 2024[123]). AMMC also participates in the Copper Mark Framework (though its performance has not yet been independently assessed at time of writing), which requires companies to undertake due diligence (The Copper Mark, n.d.[124]). The government could additionally encourage SOE’s in undertaking meaningful stakeholder engagement in managing adverse impacts: the sustainability report of Uzbekneftegaz illustrates this approach (Uzbekneftegaz, 2023[120]).

Box 4.2. A strategic approach to promote ESG risk management in state-owned enterprises

The government of Uzbekistan has taken a range of measures to enhance the performance of state-owned enterprises in managing environmental, social, and governance risks.

• Policy objectives: In 2022, the government set an objective to promote wider environmental, social, and governance (ESG) management in SOEs (Republic of Uzbekistan, 2022[116]). Its Voluntary National Review on the SDGs indicated an ambition to create “a rating of companies that comply with ESG principles” (Government of Uzbekistan, 2023[16])

• Corporate governance rules: Updated corporate governance rules include RBC requirements and are explicitly based on the OECD Guidelines for Corporate Governance of SOEs (UzAssets, 2023[117]). Rules require, among others, that SOEs adopt adequate environmental, social, and labour standards; develop a stakeholder policy; and implement a code of ethics.

• Sustainability reporting: Since mid-2024, SOEs are required to report annually on ESG. Oversight agency UzSAMA has developed methodological guidelines and provides support to SOEs in defining the scope of reporting. Sample indicators clarify that reporting should encompass risks that businesses create for people, planet (including biodiversity) and society (UzSAMA, 2024[94]).

• Strategic support: Government agency UzAssets has developed a roadmap to promote ESG risk management in SOEs (UzAssets, 2024[118]). This encompasses gaps analyses in environmental, social, and governance areas; support for the development of relevant company policies; and integration into management systems, audits, and reporting. Key performance indicators include carbon intensity, water usage, emission of pollutants, waste generation, work-related accidents, and financial disclosure in line with international standards.

• Complaint procedure: Since 2017, SOEs are under a legal obligation to establish a complaints procedure (Republic of Uzbekistan, 2017[119]). This allows affected stakeholders to raise concerns. Some SOEs provide detailed information about the procedure in their sustainability reporting.

Source: Republic of Uzbekistan (2017[119]), Law ZRU-445 on Amendments and Additions to the Law of the Republic of Uzbekistan on Appeals of Individuals and Legal Entities, https://lex.uz/docs/3336171. Republic of Uzbekistan (2022[116]), Presidential Edict on Next Reforms to Create Conditions for Stable Economic Growth by Improving the Business Environment and Developing the Private Sector, https://lex.uz/ru/docs/5947782#5950708. Government of Uzbekistan (2023[16]), Voluntary National Review of the Republic of Uzbekistan 2023, https://hlpf.un.org/sites/default/files/vnrs/2023/VNR%202023%20Uzbekistan%20Report.pdf. UzSAMA (2024[94]), Recommended actions to introduce the practice of developing and disclosing reports on CSR and ESG principles, https://davaktiv.uz/oz/menu/tipovye-dokumenty. UzAssets (2024[118]), Roadmap for sustainable development aligned with ESG principles, https://uz-assets.uz/en/presentations/.

4.2.4. Promoting stakeholder participation and access to remedy

As infrastructure can create significant beneficial and adverse impacts for local communities, enterprises’ meaningful engagement with stakeholders throughout the infrastructure life cycle is essential.

Stakeholder engagement

Opportunities for stakeholder engagement could be further strengthened. For urban planning, public participation is mandatory under the law. This can provide valuable insights for urban infrastructure development at an early stage. Consultations on Samarkand’s Green City Action Plan are an example of this (EBRD, 2023[125]). At project level, early consultations are also mandatory for high-risk projects under the Law on Environmental Impact Assessments. This could be enhanced by opportunities for feedback throughout the project implementation (World Bank, 2023[53]). Accession to the UNECE Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters, currently under consideration, could help move in this direction (UNECD, 2023[126]). The government and UzAssets could also support meaningful stakeholder engagement by state-owned enterprises. This is not yet part of UzAssets’ strategy to support SOEs on ESG although reporting guidelines for SOEs recommend including information on stakeholder engagement in their ESG reporting. The new Law on Subsoil requires public consultation ahead of mining projects but does not include further provisions on meaningful stakeholder engagement in line with OECD standards7, for instance, related to participatory monitoring (Republic of Uzbekistan, 2024[70]).

Greater civic space can enable stakeholders’ stronger participation in infrastructure investments. UN human rights institutions and UN member states recommended that Uzbekistan address restrictions to freedom of association and freedom of opinion, including harassment of human rights defenders (UN Human Rights Council, 2023[45]) (OHCHR, 2023[127]) (UN Human Rights Committee, 2020[128]). Without adequate civic space, local communities affected by infrastructure projects, and media and civil society organisations may not raise concerns they have about infrastructure projects. This makes it more challenging to identify adverse impacts on people and environment, ultimately decreasing infrastructure’s contribution to sustainable development.

Access to remedy

Different mechanisms provide access to remedy. Courts are particularly relevant for disputes on labour rights such as wage payments (OECD/ADB, forthcoming[13]). While Uzbekistan does not have a dedicated grievance mechanism for RBC‑related issues, its National Human Rights Institution plays a role in remedying violations. The Authorized Person of the Oliy Majlis of the Republic of Uzbekistan for Human Rights and its regional representations intercede on behalf of citizens and prompt actions by the government or judgments in court. In the first nine months of 2024, more than 14 000 appeals were submitted to the Human Rights Ombudsman (Human Rights Ombudsman, 2024[129]). Many concern labour rights and, in particular, wage payments and violations of environmental standards. Trade unions offer a legal clinic and support court cases of labour rights violations (OECD/ADB, forthcoming[13]).

Further promotion of operational-level grievance mechanisms is important. Cases against infrastructure projects from development finance institutions illustrate the usefulness of these mechanisms as they enable dialogue and solutions to be identified, for instance, in a complaint regarding a wind farm and possible effects on biodiversity (EBRD, 2024[67]). State-owned enterprises (as other public institutions) are obliged by law to have a complaint mechanism and some also publish information on how they handle complaints. In commercial enterprises, complaint mechanisms seem to be less frequent.

4.3. Conclusions

Uzbekistan has important strengths it can build on to advance responsible business conduct (RBC) for sustainable infrastructure development. It also has opportunities to address gaps in its policy framework and further promote responsible business conduct in the infrastructure life cycle. To contribute to an enabling regulatory and policy environment for RBC in infrastructure development, the Government of Uzbekistan could consider the following actions:

• Capitalise on the current dynamic to promote and enable responsible business conduct in co‑ordination with all actors: Infrastructure-related ministries and agencies in the Uzbek government already undertake a range of efforts to promote RBC but are not yet co-ordinated. The government should clarify institutional responsibilities and put in place mechanisms to ensure co‑ordination across government and key stakeholders on the promotion of RBC. The government should seize important opportunities in this regard. These are the finalisation and implementation of National Action Plan for Business and Human Rights and integrating the promotion of RBC in the draft strategy for small and medium-sized enterprises (SME) development.

• Enable meaningful engagement with stakeholders: The government should ensure there is adequate civic space for local communities, environmental, and human rights defenders, and civil society organisations so they can fully participate in the identification of risks and solutions to the adverse impacts of infrastructure.

• Step up efforts to prevent and mitigate violations of labour rights: International bodies have highlighted concerns about the freedom to establish unions, collective bargaining, and the effectiveness of labour inspections. Uzbekistan should fully implement related recommendations in collaboration with social partners and ensure that the new framework for public inspections strengthens the effectiveness of labour inspections.

• Continue efforts for environmental compliance: Recent legal and policy measures provide a good basis to enhance environmental compliance. The government should ensure that these measures are fully implemented. Verifying that environmental impact assessments are diligently carried out and adequately resourcing inspection services to monitor and enforce environmental standards are particularly important.

• Promote anti-corruption efforts: With the planned expansion of natural resource extraction, attention to anti-corruption will be even more important in developing and operating related infrastructure. The government should step up efforts towards transparency of economic actors, both state-owned and commercial. Participating in the Extractive Industries Transparency Initiative could be a valuable step in this direction. The OECD Monitoring under the Istanbul Anti-corruption Action Plan provides Uzbekistan with clear recommendations to strengthen anti-corruption and business integrity.

As a key economic player, especially in its roles as investor, sponsor, and operator of infrastructure, the Government of Uzbekistan could also consider mainstreaming specific tools to address RBC-related risks and impacts at the infrastructure project-level.

• Build on efforts to promote RBC in state-owned enterprises (SOEs): The government should ensure the full implementation of its environmental, social, and governance (ESG) strategy for SOEs in infrastructure sectors. It should consider including in its strategy measures to further encourage RBC due diligence in SOEs, including their engagement with stakeholders and business partners on RBC.

• Reinforce expectations for public-private partnerships (PPPs): Building on the forthcoming Law on Investment with its principle to promote RBC and the requirement to analyse social, economic, and environmental impacts in PPP regulations, the government should communicate its RBC expectations of private partners and ensure public authorities have adequate capacity and resources to integrate these expectations into PPPs.

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Notes

← 1.  Uzbekistan succeeded in overcoming systemic forced labour in cotton production, leading international businesses and civil society organisations to end a boycott campaign in 2022 (Cotton Campaign, n.d.[34]).

← 2.  See https://eco-service.uz/public/pages/main_conclusions.

← 3.  See https://eco-service.uz/public/pages/main_rates.

← 4.  See https://anticorruption.uz/en/about.

← 5.  See https://www.sqb.uz/esg/.

← 6.  The current text reaffirms that investors need to respect legislation such as on environmental protection and anti-corruption.

← 7.  Notably the OECD Council Recommendation on the OECD Due Diligence Guidance for Meaningful Stakeholder Engagement in the Extractive Sector [OECD/LEG/0427].