ROP: Processing Submissions

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ROP: Processing Submissions
1. Content of the Submission.
  1. The submission includes the following information:
    1. Requestors’ name, address, contact details and preferred mode of contact;
    2. Authorized Representative’s name and contact details, Requestors’ authorization to the Authorized Representative to file a submission on their behalf;
    3. Any request for confidentiality of the identity of the Requestors or of an in-country Authorized Representative or other information, and reasons for such request;
    4. Name and location of the AIIB-financed Project concerned; and
    5. Direct and material adverse environmental or social issues to be addressed.
  2. The Requestors are encouraged but not required to provide the following additional information:
    1. The provisions of the ESP the Requestors consider have not been complied with and how;
    2. Any steps the Requestors have taken to resolve the issue (e.g., approaching the Client, the Project-level GRM, Management, government, judicial or law enforcement bodies) and the outcome;
    3. The issues that are still not resolved;
    4. The Requestors’ view of the best way to solve the issue and the most satisfactory result; and
    5. Whether the Requestors are submitting a Project Processing Query, request for Dispute Resolution or request for Compliance Review.
  3. The PPM has prepared a standardized optional PPM sample submission form to guide Requestors in preparing their submissions (see Attachment 2 below). The English language submission form is downloadable from the PPM website. This form will be progressively translated into the official and national languages of AIIB Members where AIIB is currently financing Projects. The PPM help-desk can also be contacted for guidance on correctly filing a submission but does not advise on the substance of a submission.
2. Language of the Submission and Other Written Communications.
  1. The working language of AIIB is English.
  2. Submissions and subsequent communications from the Requestors to the PPM may be written in English or in any official or national language of the Requestors’ country. A submission will not be rejected on the grounds that it is written in the official or national language of the Requestors’ country.
  3. The PPM translates the substantive parts of the submission and of subsequent communications from the Requestors into English if they are not in English.
  4. The PPM’s acknowledgment of receipt of the submission is in English and in the language of the submission, if such language is not English.
  5. Thereafter, the PPM’s official written communications with the Requestors are in English.
  6. The PPM also translates the substantive part of its communications to the Requestors into the submission language, if the submission language is not English. However, the English language version of AIIB’s communications prevails in the case of a discrepancy between the English and translated version.
  7. The PPM notifies the Requestors if translation will delay submission processing and indicates new submission processing dates. Additional time required for translation will not invalidate a submission.
3. Filing the Submission.
  1. The submission may be sent to the PPM by mail, email, fax or hand-delivered to PPM.
  2. The PPM can be contacted through a dedicated PPM website, via the AIIB homepage https://www.aiib.org or by contacting the Managing Director of CEIU at:
4. General Processing Provisions Applicable to All Submissions. This section sets out actions applicable to all submissions regardless of the PPM function under which they are to be considered. Subsequent sections describe actions specific to each PPM function.
  1. Indicative Timelines:
    1. Indicative timelines for handling submissions are set forth below for each action. Attachment 3 summarizes the indicative timelines for processing submissions under each PPM function in tabular form. Working Days are defined in the Definitions (above).
    2. The PPM may extend any of these timelines during submission handling if this is essential to ensure full and proper processing of a submission. Time extension may be based on case complexity, difficulty of gathering all necessary information within the timelines specified and similar considerations.
    3. The PPM notifies the Requestors, Management and the Client, as applicable, of the extension of timeline and records it in the PPM registry.
  2. Acknowledgment of Receipt of a Submission:
    1. Upon receipt of a submission, the PPM acknowledges receipt of the submission to the Requestors (with a copy to any Authorized Representative) and initiates communication directly with the Requestors about the submission. This acknowledgement does not indicate whether a submission meets the eligibility criteria.
    2. The PPM acknowledges receipt of the submission within five (5) Working Days following submission receipt.
    3. In its acknowledgment, the PPM outlines for the function selected by the Requestors, the anticipated submission timeline, processing stages, steps for moving between stages, if necessary, and clarifies the mode of maintaining contact and any requirements for confidentiality.
  3. Request for Confidentiality; Retaliation Assessment:
    1. The PPM’s acknowledgment of receipt of the submission reminds the Requestors (and in-country Authorized Representative, if applicable) who have not requested confidentiality of information and/or identity of the option to do so (see Section 9 and Attachment 4 below on Confidentiality and Retaliation). The Requestors have ten (10) Working Days following the PPM’s acknowledgement to advise the PPM of their confidentiality requests, if any.
    2. The PPM takes any confidentiality requests, if granted under Section 9 below (on Confidentiality and Retaliation), into account in its communications with Management, the Client and any other party.
    3. The PPM also initiates a due diligence review to assess possible risk of Retaliation. Thereafter, the PPM makes all reasonable efforts to reduce the risk of Retaliation to the Requestors (see Section 9 below on Confidentiality and Retaliation).
  4. PPM Requests for Additional Information:
    1. The PPM may ask the Requestors or any other party for more information or clarification to determine submission eligibility. The PPM contacts the Requestors within ten (10) Working Days after issuing the acknowledgment of receipt of the submission and explains the additional information required and specifies the Requestors’ response time. Any such information supplied is considered as part of the submission.
    2. The PPM may temporarily suspend submission processing to allow the Requestors to rectify submission oversights that would otherwise invalidate the submission. The PPM informs the Requestors of this and the additional Working Days allocated for re-submission.
  5. Screening for Eligibility; Registration:
    1. The PPM determines whether the submission meets the eligibility criteria set out above in Section 5.1 (General Eligibility Criteria Applicable to all Submissions). If the submission does not indicate a preferred PPM function to be pursued, or if it appears to indicate an inappropriate function, the PPM contacts the Requestors and recommends the most suitable processing option based on submission content, timing and eligibility criteria, taking the Requestor’s proposal, if any, into account. The Requestors’ decision on which process they wish to pursue is, however, final, subject to the submission meeting the applicable requirements of Section 4 (Time Limits for Filing a Submission) and Section 5 (Eligibility of Submissions).
    2. Different indicative time periods for the PPM’s eligibility determination apply depending on the PPM function pursued and are outlined below under the section on the relevant function. Once the PPM has reached its determination, it prepares an eligibility determination report, which includes the names of the Project, country and Requestors (unless a request for confidentiality has been granted by the PPM), a brief description of the nature of the submission, the reason for the PPM’s determination and any actions to be taken in light of the submission. The PPM sends its eligibility report to the Requestors and Management promptly upon its preparation.
    3. If the PPM determines that the submission meets the general eligibility criteria in Section 5.1 (General Eligibility Criteria Applicable to All Submissions) above, it registers the submission in the PPM registry within five (5) Working Days following the preparation of its eligibility report, and at the same time issues the report, together with the submission and its acknowledgement of receipt, to the Board of Directors and Management. Unless it has granted a request for confidentiality, the PPM also discloses the Requestors’ submission and the PPM’s acknowledgment of receipt and eligibility report, within ten (10) Working Days following their circulation to the Board and Management.
    4. If the PPM determines that the submission does not meet these eligibility criteria, it so informs the Board of Directors and Management as part of its periodic reporting. It also discloses these periodic reports promptly upon their preparation.
    5. If the PPM determines that the submission does not meet the general eligibility criteria in Section 5.1 1 (General Eligibility Criteria Applicable to All Submissions) above, the PPM endeavors, as appropriate, to direct the Requestors to the appropriate unit within AIIB that can handle issues raised in the submission. For example, a submission concerning fraud, corruption or other Prohibited Practices is referred to the CEIU integrity staff. If a submission concerns only a request for information within AIIB’s possession and does not allege a concern or dispute or violation of the ESP, that request is handled under AIIB’s Policy on Public Information and not by the PPM. The PPM follows up with the relevant unit in AIIB to facilitate a timely and informed response to the submission. However, the Requestors have sole responsibility for meeting any time limits or deadlines set by such other policy or unit in AIIB.
    6. If a request for Compliance Review is determined to be ineligible because it has been filed before approval of the Financing, the MD-CEIU forwards the submission to Management and records the referral in the PPM registry. Management considers these submissions during Project preparation and copies MD-CEIU on any response to the Requestors.
  6. Site Visits:
    1. The PPM may, unless the Member in which the Project is located objects, undertake site visits to the Project area at any time after a submission has been filed, in order to better understand submission issues and possible ways to address them. Site visits may involve meeting with the Client, Requestors, relevant government representatives and other interested parties, as well as gathering and providing information. The PPM may engage local interpreters and other persons to facilitate meetings and interviews with Project-affected people. AIIB personnel and Client staff and other interested parties may also provide information to support the site visit.
    2. It is expected that Members will allow timely PPM site visits in the spirit of AIIB’s partnership with its Members. The PPM seeks AIIB Member concurrence to undertake a site visit to the Project area through the responsible AIIB operational department (following the usual approach for operational travel by AIIB personnel to the Member’s territory) on a Project-by-Project basis to facilitate the proper resolution of submissions through the PPM. The PPM seeks the assistance of AIIB Management and the Board Member representing the AIIB Member concerned, as necessary, to obtain any required visas and clearances for site visits by PPM staff, Project-specific task force members and external specialists engaged for this purpose. If a Member rejects a site visit request, the PPM informs the Board of Directors and conducts its review on the basis of the available evidence.
5. Project Processing Queries.
  1. Project Processing Queries can help Management to identify and handle potential issues early, when they may be more amenable to resolution. However, Project Processing Queries can become matters of Dispute Resolution if the issues in question turn out to be more complex than originally understood.
  2. Project Processing Queries are handled as promptly as possible to facilitate resolution of concerns during Project preparation. Under this procedure, the PPM does not assess whether or not AIIB is in compliance with the ESP.
  3. The procedures for consideration of Project Processing Queries are as follows:
    1. Eligibility Report. The PPM prepares its eligibility report within ten (10) Working Days following its acknowledgment of receipt of the submission.
    2. Management Response. If the PPM determines the submission is eligible, Management prepares and provides a response to the PPM, with a copy to the Client, within fifteen (15) Working Days following Management’s receipt of the eligibility report from the PPM (see Section 6.4.5 above on Screening for Eligibility; Registration). The PPM promptly sends Management’s response to the Requestors.
    3. Constructive Dialogue. The PPM facilitates constructive dialogue between Management, the Client, the Requestors and any other relevant parties to identify solutions to address the concerns raised. This dialogue should be completed as soon as possible before approval of the Financing.
    4. Termination of the Process. The Requestors may terminate the process at any time and submit a request for Dispute Resolution instead, subject to the submission meeting the applicable requirements of Section 4 (Time Limits for Filing a Submission) and Section 5 (Eligibility of Submissions).
    5. Disclosure of a Summary. Within ten (10) Working Days following completion or termination of the Project Processing Query, the PPM prepares and discloses a summary of the actions taken under this process.
6. Requests for Dispute Resolution.
  1. The Dispute Resolution process aims to resolve a dispute that has arisen over measures required of the parties to the dispute to mitigate known and quantifiable, potential or actual material adverse environmental or social impacts that arise during AIIB’s due diligence of a Project or during Project implementation. The parties to the dispute typically include the Client and the Requestors but may also involve Management and/or contractors or other parties involved in Project processing or implementation.
  2. As with Project Processing Queries, under this procedure, the PPM does not assess whether or not AIIB is in compliance with the ESP. The PPM explores with the concerned parties mutually acceptable dispute resolution methods and may hire professional dispute resolution and subject-matter specialists to facilitate the dispute resolution process. This process may include consultative dialogue, information sharing, joint-fact finding, creation of a mediation mechanism or other methods. The PPM coordinates and guides the parties during the agreed dispute resolution process.
  3. The PPM also facilitates reaching a time-bound and monitorable dispute resolution agreement or memorandum of understanding between the parties concerned and arrangements for monitoring its implementation.
  4. The procedures for Dispute Resolution are as follows:
    1. Eligibility Report. The PPM prepares its eligibility report within twenty (20) Working Days following its acknowledgment of receipt of the submission. It promptly sends its report to the Requestors and Management.
    2. Management Response. If the PPM determines that the submission is eligible, Management prepares and provides its response to the PPM, with a copy to the Client, within fifteen (15) Working Days following Management’s receipt of the eligibility report from the PPM (see Section 6.4.5 above on Screening for Eligibility; Registration). The PPM promptly sends Management’s response to the Requestors.
    3. Consent for Dispute Resolution. The PPM then seeks the consent of the parties to the dispute to undertake Dispute Resolution. It facilitates reaching an agreement about the approach and methodology, as well as the issues to be addressed and timeline for the Dispute Resolution process, and documents the agreed approach, issues and timeline. The PPM facilitates and documents the agreement within thirty (30) Working Days after receiving Management’s response.
    4. Dispute Resolution Agreement. The PPM aims to facilitate the formulation and signing of a Dispute Resolution agreement. This agreement contains a time-bound, monitorable implementation schedule for specific agreed actions.
    5. Disclosure of the Dispute Resolution Agreement. If the parties agree to disclosure of the Dispute Resolution agreement, the PPM discloses it within ten (10) Working Days following its signature. If the parties do not agree to its disclosure, the PPM prepares and discloses a summary of the Dispute Resolution process and its outcomes within the same time period.
    6. Monitoring of the Dispute Resolution Agreement. The PPM monitors and reports to the Board of Directors on the implementation of actions agreed in the Dispute Resolution agreement (including for Project scoping or other changes) in accordance with the agreed schedule, and publicly discloses these reports within ten (10) Working Days following their circulation to the Board.
    7. Absence of a Dispute Resolution Agreement. The PPM encourages the parties to the dispute to reach agreement. However, if agreement is unlikely to be reached within ninety (90) Working Days following Management’s response, the PPM may terminate the Dispute Resolution process.
    8. Termination of the Process. Any party to the dispute may terminate the Dispute Resolution process at any stage in the process. In such a case, the Requestors may submit a request for Compliance Review, subject to the submission meeting the applicable requirements of Section 4 (Time Limits for Filing a Submission) and Section 5 (Eligibility of Submissions).
    9. Summary of the Process in Absence of a Dispute Resolution Agreement. If no Dispute Resolution agreement is reached, the PPM prepares a summary of the Dispute Resolution process and its outcomes, circulates it to the Board within 10 Working Days of the termination of the process and publicly discloses it within ten (10) Working Days following circulation of the summary to the Board.
7. Requests for Compliance Review.
  1. As noted in Section 4.3 above, requests for Compliance Review, are designed: to investigate allegations by Project-affected people that AIIB has failed to comply with its obligations under the ESP in its environmental and social due diligence of a Project during Project preparation or its oversight of the Project during implementation, thereby causing or being likely to cause material adverse environmental or social impacts on the Project-affected people; and if the allegations are substantiated, to review any action plan proposed by Management to address these impacts. Consequently, unlike Project Processing Queries or Dispute Resolution, under the Compliance Review process the PPM assess whether or not AIIB is in compliance with the ESP.
  2. Under this procedure, the PPM assesses whether:
    1. The facts alleged are substantiated.
    2. A direct causal link exists between the adverse impact and alleged AIIB noncompliance with the ESP.
    3. The alleged adverse impact is material.
    4. Management has adequately explained its actions pursuant to the ESP.
    5. The actions proposed by Management to resolve the issues raised in the submission are appropriate.
  3. The procedures for Compliance Review are as follows:
    1. Eligibility Report. The PPM prepares its eligibility report regarding the eligibility criteria under Section 5.1 (General Eligibility Criteria Applicable to All Submissions) within twenty (20) Working Days following its acknowledgement of receipt of the submission. This timeframe may be extended if the PPM concludes that this eligibility assessment cannot occur without a site visit.
    2. Management’s Response to the Submission. If the PPM determines that the submission meets these general eligibility criteria, Management prepares its response to the submission, including: (i) Management’s views, if any, as to whether the submission meets the submission’s eligibility criteria set out in Section 5.2 (Additional Eligibility Criteria for Compliance Reviews); and (ii) any actions proposed by Management to address the issues raised in the submission. Management provides the PPM with its response within thirty (30) Working Days following receipt of the eligibility report from the PPM (see Section 6.4.5 above on Screening for Eligibility; Registration). If requested by Management, this timeframe may be extended by the PPM if the PPM considers that the complexity of the submission so requires. This response may also detail the actions Management has taken in accordance with the ESP, its engagement with the Project-affected people, and its proposed actions to address issues raised in the submission.
    3. Recommendation to the Board. Within thirty (30) Working Days following its receipt of Management’s response, the PPM determines whether the submission meets the additional eligibility requirements applicable to Compliance Reviews set out in Section 5.2 (Additional Eligibility Criteria for Compliance Reviews) and decides whether to recommend that the Board approve the commencement of the Compliance Review. This decision is based on information in the submission, Management’s response and additional information obtained during site visits, from the Board Director representing the Member concerned and any local authorities or agencies involved in the Project. The PPM may decide that another course of action in lieu of a Compliance Review is appropriate. In such a case, it also decides whether approval by the Board of Directors of such course of action is required. The PPM does not make any definitive findings on issues of compliance or the adverse impact suffered by the Project-affected People at this stage. Any definitive findings are made in the final Compliance Review Report.
    4. Board Consideration. If the PPM decides to recommend approval of the commencement of the Compliance Review or other appropriate course of action, it promptly submits its recommendation to the Board for approval. If the PPM decides not to recommend a Compliance Review or other course of action to the Board for approval, or if it decides on another course of action but decides that Board approval is not required, it promptly submits to the Board of Directors and to Management for information a report explaining its decision.
    5. Notification to Requestors and the Client. The PPM informs the Requestors of the decision of the Board of Directors within five (5) Working Days following the Board’s consideration. Management informs the Client of the decision of the Board of Directors within the same period. If the PPM decides not to recommend a Compliance Review or other course of action for Board approval or decides on another course of action but decides that Board approval is not required, it informs the Requestors promptly upon its submission to the Board of its information report explaining its decision, and Management informs the Client accordingly.
    6. Disclosure of the Board Decision; Report to the Board. If the PPM decides to recommend approval of the commencement of the Compliance Review or other appropriate course of action, it discloses the decision of the Board of Directors within ten (10) Working Days following the decision. If the PPM decides not to recommend a Compliance Review or other course of action for Board approval or decides on another course of action but decides that Board approval is not required, it discloses its report to the Board explaining its decision within ten (10) Working Days following submission of the report to the Board.
    7. Terms of Reference (TOR). If the Board approves a recommendation to commence the Compliance Review, the PPM prepares draft TOR for the Compliance Review within fifteen (15) Working Days following the Board’s decision and seeks comments on the draft TOR from the Policy and Strategy Committee of the Board of Directors. The PPM considers the comments received and promptly submits the final TOR to the Board of Directors for information. The TOR outline the scope and methodology for the Compliance Review, its timeframe, budget, language arrangements, skills and expertise needed for the Project-specific task force. The PPM discloses the final TOR within ten (10) days following submission of the final TOR to the Board.
    8. Project-specific Task Force. Thereafter, the PPM promptly engages the necessary specialists and forms a Project-specific task force to conduct the Compliance Review. The MD-CEIU chairs this task force.
    9. Compliance Review. The PPM initiates the Compliance Review within thirty (30) Working Days following Board approval. The Requestors, the Client, any local authorities and agencies involved in the Project, the Board Director representing the Member concerned, Management and other AIIB staff are provided an equal opportunity to be heard during the Compliance Review. After the PPM’s fact-finding, each of these parties is given an opportunity to discuss or counter any fact or allegation that may adversely affect them.
    10. Arbitral or Judicial Proceedings. If at any point during the Compliance Review, the PPM learns of arbitral or judicial proceedings involving substantive issues raised in the submission, the PPM assesses the implications of such parallel processes and submits a recommendation to the Board of Directors on whether to continue with the Compliance Review. As an interim measure, the PPM may suspend the Compliance Review until the Board of Directors decides on the matter.
    11. PPM Draft Compliance Review Report. Upon completion of the Compliance Review, the PPM prepares, with the assistance of the Project-specific task force, a draft Compliance Review report. The draft Compliance Review report includes findings on the matters noted above in Section 6.7.2, as relevant.
    12. Assessment of Impact can be a Complex Matter. The Project-specific task force takes the without-project scenario as the base case for comparison, taking into account any available baseline information. Nonaccomplishments and unfulfilled expectations that do not generate a material deterioration compared to the without-project scenario are not considered as a material adverse impact for this purpose. As the assessment of material adverse impact in the context of the complex reality of a specific Project can be difficult, careful judgment on these matters by the Project-specific Task Force, and guidance from the ESP, are required. Issues of causation also require careful attention and exercise of judgment to determine if the impact in question is partially or wholly caused by noncompliance.
    13. Circulation of the PPM Draft Compliance Review Report. The PPM prepares and circulates the draft Compliance Review report within sixty (60) Working Days following commencement the Compliance Review. This time frame may be extended if the PPM concludes that the complexity of the submission so requires. The PPM circulates the draft report to the Requestors for comment and to Management for a response. Management promptly circulates the draft Compliance Report to the Client for comment.
    14. Review of the Draft Compliance Review Report if no Noncompliance was Found. If the Compliance Review report concludes with no findings of noncompliance, the Client has fifteen (15) Working Days following its receipt of the draft Compliance Review report to provide its comments on the draft report to Management. Management finalizes and provides its response to the PPM within thirty (30) Working Days following Management’s receipt of the draft Compliance Review report. The Requestors have thirty (30) Working Days following their receipt of the draft Compliance Review report to provide the PPM any comments on the draft report.
    15. Review of Draft Compliance Review Report if Noncompliance was Found. If the PPM determines that there has been noncompliance with the ESP, the Client and the Requestors have forty-five (45) Working Days following circulation of the draft Compliance Review report to provide any comments on the draft report. The Client provides its comments to Management, and the Requestors provide their comments to the PPM. If the Requestors agree, the PPM shares their comments with Management in order to help inform Management’s finalization of its response (including its Management Action Plan) (see below).
    16. Management Action Plan (MAP). If the PPM determines that there has been noncompliance with the ESP, Management updates its response, and also prepares and circulates to the Client and Requestors, as well as the PPM for comment, a proposed MAP within ninety (90) Working Days following Management’s receipt of the draft Compliance Review report. If requested by Management, the PPM may extend this timeframe if it considers that the complexity of the submission so requires. The MAP includes actions to address findings of noncompliance set out in the PPM’s draft Compliance Review report. Management seeks the Client’s agreement on the elements of the MAP that are within the Client’s responsibility and also consults with the PPM in preparing its MAP. Management also seeks (but is not required to reach) agreement with the Requestors on the MAP. Once Management has prepared and circulated the proposed MAP, it provides the Requestors and PPM at least fifteen (15) Working Days following their receipt of the MAP to provide their comments to Management. Within thirty (30) Working Days following the deadline for the Requestors and the PPM to provide comments, Management updates its MAP taking into account any comments received and agreement reached, and sends its updated Management response, including the updated MAP, to the PPM.
    17. Final Compliance Review Report. The PPM, with the assistance of the Project-specific task force, finalizes the Compliance Review report, taking into account Management’s response (and MAP, if one is required pursuant to Section 6.7.3 (p) above) within fifteen (15) Working Days after its receipt of Management’s response (and draft MAP, if one is required) and sends it back to Management. The final Compliance Review report includes a summary of how the report has responded to comments and responses received.
    18. Final MAP. Management finalizes the MAP (if one is required pursuant to Section 6.7.3 (p) above) to address the findings of noncompliance in the final Compliance Review report. The MAP includes a summary of how Management has taken into account the Compliance Review report and addressed any comments from the Client, the Requestors and the PPM. Management sends its final MAP to the PPM within fifteen (15) Working Days following Management’s receipt of the final Compliance Review report.
    19. Board Consideration. The PPM promptly submits to the Board of Directors its final Compliance Review report. Management’s response and the final MAP (if one is required pursuant to Section 6.7.3 (p) above) are attached to the final Compliance Review report. The MAP is subject to the approval of the Board of Directors.
    20. Disclosure. If the PPM makes no findings of noncompliance, the Final Compliance Review report, together with Management’s response, are circulated by the PPM to the Requestors and to the Board for information, and by Management to the Client; these are publicly disclosed by the PPM within ten (10) Working Days following their circulation to the Board. If the PPM makes findings of noncompliance, the final Compliance Review Report, together with Management’s response and the Board-approved MAP, are circulated by the PPM to the Requestors and by Management to the Client and are disclosed by the PPM within ten (10) Working Days following the Board’s decision.
    21. MAP Monitoring. Management monitors the implementation of the MAP and submits monitoring reports to the Board of Directors in accordance with timelines specified in the MAP. The PPM reviews Management’s monitoring reports and prepares a status report on MAP implementation, at least annually. The PPM’s review involves seeking views from Management, the Client and Requestors and considering any information received from the public or other sources. The PPM forwards its draft periodic MAP status reports to the Board of Directors and considers any comments received before finalizing the report. The PPM discloses each report within ten (10) Working Days after its circulation to the Board.