Many development banks have created independent offices to receive complaints from communities affected by the projects they finance. They were created after people around the world demanded that banks be held accountable for the harm that they caused to people and the environment. For that reason, these offices are often referred to as accountability mechanisms. The requirements for submitting a complaint vary slightly depending on the accountability mechanism, as do the services that the mechanism can offer (see below for specific information about each mechanism).
What can you expect if you file a complaint? In general, the mechanisms can offer to convene a dialogue between you and the bank’s client, or they can conduct an investigation to determine if the bank’s policies have been violated, or both. It is important to remember that the mechanisms generally do not have the authority to stop a project, which is something only bank management can do. But you might be able to make some changes to the project or receive compensation you are owed. Unfortunately, it’s possible that nothing will change as a result of the complaint. Usually you will have more success if the complaint is part of a larger campaign or strategy that includes talking with your government and the media.
If you decide you want to submit a complaint, there are several organizations and resources that can help. Contact us for additional information. We also encourage you to take a look at the accountability mechanism guides here and here that our members Accountability Counsel and SOMO have developed. These guides describe the process for bringing a complaint at each of the accountability mechanisms and provide useful advice and suggestions along the way.
Here are the basic steps to prepare a complaint and a few things you should consider:
1. Gather Information
Talk with others in your community about the impacts you have experienced due to the project. You should also try and gather any news or NGO reports on the project or scientific studies of the project’s impacts. Consider documenting the impacts of the project in interviews with people in your community or by taking photos or videos. If you would like to publish your documentation work, share it with us to include on the website.
If you found the project that affects you on the EWS map, then you already know the project name and number and have access to the documents that the bank has published. You’ll also want to look at the policies of the bank that is financing the project to identify which requirements the bank or its client might have violated.
2. Make sure you meet the requirements to submit a complaint.
Some mechanisms, like the World Bank’s Inspection Panel, require that you first raise your concerns with World Bank staff. You can do this by meeting with them or sending a letter. (Make sure you keep copies of the letters you send and meeting notes!) For several mechanisms, you must bring your complaint within a certain window of time. If you’ve just learned about the project on this website, you’re probably still within this window. See the filing requirements for each mechanism, at the links below, for more information.
3. Identify what you want from the process.
You should decide whether you want to engage in a dialogue (sometimes called mediation or problem-solving) with the bank’s client, if the mechanism you’re dealing with offers that service. Alternatively, you can decide to ask for an investigation (sometimes called compliance review) into whether the bank’s policies were violated. In some cases, it may not be possible to ask for both. Here are a few things to consider:
• If you want to enter into a dialogue with the bank’s client, what is it that you want to get out of it? If you oppose the project completely, a dialogue might not be the best option. If you are interested in dialogue, you and your community will need to be prepared to dedicate your time to participate in the dialogue. It’s a lot of work and can sometimes take a long time! You’ll need to decide collectively who will represent your community at the dialogue table.
• If you ask for an investigation, you will likely not be very involved in the process, and it could take a year or more before you see the report. In response to the report, the bank will normally develop an action plan to make any changes to the project that might be necessary. It’s important that the bank hears whether you think the plan is good enough to prevent harm.
4. Decide if you want to request that the mechanism keep your identity confidential.
The mechanisms won’t accept anonymous complaints, but you can ask that they keep your identity confidential if you’re concerned that you would face retaliation or threat for bringing a complaint.
A word on safety: Only you and your community can decide if you feel safe to submit a complaint to a grievance mechanism. A complaint may anger your government or a project company, but a complaint might also help to bring international attention to your situation and protect community members from harm. Every situation is different, and you should be sure to make the decision that makes sense for your community.
5. Write your complaint.
Most of the mechanisms have a template or form that you can fill out to make sure you provide all of the information they need to consider your complaint.
Below are links to all of the bank’s mechanisms.
There are other complaint mechanisms available that are not associated with the banks. If you’re concerned about the actions of your government, you may bring a complaint to a human rights body. If the company involved in the project is from an Organisation for Economic Co-operation and Development (OECD) country, you could bring a complaint under the OECD Guidelines for Multinational Enterprises. And some national finance institutions, like export credit agencies, which may be co-financing the project, have their own complaints mechanisms. The Accountability Resource Guide written by Accountability Counsel has more information about these mechanisms.
African Development Bank: Independent Review Mechanism
The Independent Review Mechanism (IRM) offers both compliance review and mediation. Information on how to submit a complaint can be found here. The IRM’s Operating Rules and Procedures can be found here. A guide put together by SOMO and Accountability Counsel to help explain and assist with the process can be found here.
Asian Development Bank: Accountability Mechanism
The ADB’s Accountability Mechanism offers compliance review through the Compliance Review Panel and mediation through the Special Project Facilitator. You can find out more about filing a complaint here. The full policy and procedures of the mechanism are here. The Accountability Mechanism has also developed a brochure describing the complaint process and a summary with more information about difference between the two functions. The AM also provides a link to a sample complaint.
European Bank for Reconstruction and Development: Project Complaint Mechanism
The Project Complaint Mechanism offers both mediation and compliance review. You can learn how to submit a complaint here. The PCM provides a sample complaint both in English and Russian. The PCM has published a User’s Guide and leaflet describing its complaint process. You can also read the PCM’s detailed rules of procedure.
European Investment Bank: Complaints Mechanism
The Complaints Mechanism can involve either mediation or investigation. It is unique among all of the mechanisms listed here in that it is the only one that has an appeals process. If you are unsatisfied with how the Complaints Mechanism resolved your case (or didn’t resolve your case), you can appeal to the European Ombudsman. For more information, see the CM’s online complaints form, flyer (in multiple languages), and rules of procedure.
Inter-American Development Bank: Independent Consultation and Investigation Mechanism
As the name suggests, the Independent Consultation and Investigation Mechanism (ICIM) offers both mediation and compliance review. You can find information on filing a complaint, on ICIM’s Frequently Asqued Questions (FAQs), or on the Public Registry. The MICI Policy for the Inter-American Development Bank (IDB) or the Multilateral Investment Fund (MIF) operations can be found here. The MICI Policy for the Inter-American Investment Corporation (IIC) operations can be found here.
International Bank for Reconstruction and Development and the International Development Association (World Bank Group): Inspection Panel
The Inspection Panel has the distinction of being the first accountability mechanism created at any of the MDBs. The Inspection Panel only offers compliance review. The complaint process is described here, and the requirements for filing a complaint here. The Inspection Panel’s brochure is available in twelve languages.
International Finance Corporation and the Multilateral Investment Guarantee Agency (World Bank Group): Compliance Advisor Ombudsman
The Compliance Advisor Ombudsman (CAO) receives complaints from communities affected by the private sector arm of the World Bank, the International Finance Corporation and the Multilateral Investment Guarantee Agency. The CAO provides both mediation and compliance review services. The CAO just recently updated its Operational Guidelines, on the last page of which you will find a form that you can use to prepare your complaint. You can also find the requirements for filing a complaint here.