Stakeholder dialogue

FMO's decisions affect others and vice versa. We discuss key matters with a diverse set of stakeholders and factor the outcomes into our decision-making, strategy and reporting. We have identified our key stakeholders based on their (economic) relationship with FMO, their interest in and influence on FMO, the extent to which they are affected by FMO’s activities as well as the potential for sharing knowledge. We explain how we have engaged with each stakeholder group and the topics that were discussed. FMO also takes part in several business and impact initiatives to promote sustainable development and responsible business across the globe. Please refer to Our Commitments for an overview of our main engagements.

State of the Netherlands and other shareholders

FMO was founded as a public-private partnership with 51% of shares held by the State of the Netherlands. Our mandate is to promote private sector development in developing countries, which is in line with the Dutch government’s policy on foreign trade and development cooperation. The Dutch government provides a guarantee on our financial commitments and entrusts FMO with the management of several government funds that have a strong synergy with FMO’s overall strategy.

The Management Board (MB) regularly discusses performance on our strategy with the government. Key topics discussed in 2020 include:

  • Customer support in response to COVID-19 and the impact of the pandemic on land rights;

  • The Joint Agenda between FMO and the Government, including FMO’s involvement in fragile states, ESG and stakeholder engagement, as well as additionality and mobilization;

  • FMO advice on the Dutch Africa Strategy;

  • Our draft position statement on phasing out fossil fuels from direct investments;

  • Revision of the Criteria Memorandum – an agreement between FMO and the Government covering criteria used for investment decisions, looking at countries, sectors, ESG and additionality.

In addition, we engage with our network of Dutch embassies in the countries in which we operate for contextual analysis, guidance and information sharing.

The remaining 49% of our shareholders’ capital is provided by commercial banks, trade unions and other private sector parties. Our shareholders lay the foundation for FMO’s financial sustainability. We engage with our minority shareholders mainly through the Annual General Meeting. Important topics discussed included FMO’s financial and risk management, development impact and accountability of our activities.

Supervisor and regulator

The DNB supervises FMO to ensure we comply with banking regulations and manage risks in line with our risk appetite. The main topic in 2020 was FMO’s responsibility for preventing financial and economic crime. In 2020, DNB conducted an on-site inspection to determine our progress towards complying with the Wwft. DNB concluded that FMO was on the right track, but that progress was not fast enough. As a result, FMO and DNB agreed on a deadline to ensure full compliance with the Wwft and Sanctions Law by the end of 2021.


Our customers consist of companies, financial institutions, private equity fund managers, and agribusiness and energy project developers in developing countries. Through their business activities, they have an impact on the economy and local communities. We support our customers to realize positive impact by providing finance and ESG support.

FMO investment staff as well as our MB are in close contact with customers. In 2020, due to the pandemic, our annual face-to-face meetings with customers were conducted virtually. Not surprisingly, the main topic of conversation was how FMO could support customers through these difficult times. Each year, we also send out a customer satisfaction survey.


Our employees and management contribute to the realization of FMO's objectives. Directors and managers are involved in the annual strategy review to ensure we continue to realize our mission. Employees expect a fair salary, a safe and motivating work environment and equal opportunities for professional development.

During 2020, the MB regularly connected with FMO employees via virtual all-staff meetings and dialogue sessions held in smaller groups. The MB also attended the scheduled meetings with the Works Council. The main topics discussed were building trust, employee well-being while working from home during the pandemic and how to create an inclusive organization.


Investors include FMO’s bondholders as well as public and private investment partners. We offer investors access to our expertise on responsible investing in emerging markets. Institutional and private investors are interested in the risk-return profile of their investments and the development impact created through them. Therefore, we provide regular financial and impact reports. Our investors expect FMO to be responsible, transparent, and accountable. We have demonstrated this by obtaining the highest ESG risk rating in the banking industry (966 banks) and in the total population assessed ('Global Universe'=12,781) by Sustainalytics, and by receiving the highest score (A+) on the UN Principles for Responsible Investment (UNPRI).

FMO frequently meets with its private investors. However, in 2020, this was less frequent due to the cancellation of several conferences and roadshows. The attention from investors this past year has been on the impact of COVID-19 on FMO’s investment portfolio and how we have dealt with the situation. Our response to the pandemic has been communicated through the website and several virtual meetings with investors. 

Our public investment partners include the Dutch state, the European Commission and the Green Climate Fund. In 2020, the focus of cooperation was on support for COVID-19-affected entrepreneurs.

Local communities, non-governmental organizations and customers of customers

Our customers are responsible for engaging with local stakeholders, to prevent harm and to maintain support for their activities. Local communities expect FMO to require customers to comply with international standards and monitor how they do. The IFC Performance Standards, for instance, requires our customers to engage with local stakeholders, set-up of grievance mechanisms and take effective remediating actions.

We engage with non governmental organizations (NGOs) that represent local environmental and human rights advocates and engage with knowledge centers and whistle blowers in the banking industry. NGOs have expressed a need for FMO to better explain how we ensure our customers safeguard human rights, natural resources and critical ecosystems. Moreover, NGOs have asked us to be more closely involved with local communities prior to making an investment decision. FMO engages with NGOs throughout our investment process when we need expertise on human rights in local contexts. With a few NGOs based in The Netherlands we have scheduled quarterly meetings to discuss a wide array of topics. The MB also engages with these selected NGOs. During 2020 the main topics discussed were:

  • Our COVID-19 response and how this has helped our customers and the environment in which they operate.

  • Through a report of the International Accountability Project and Fundeps, several NGOs asked us to improve our disclosure practice. They asked us to add project status information and a reference to the Independent Complaints Mechanism to the World Map on our website. FMO is working on this. Moreover, NGOs asked us to disclose more E&S information per individual customer and project. This supports communities’ right to seek, receive and impart information as equal partners in development. Whereas FMO fully acknowledges this right, we responded that we believe that project specific E&S disclosure and community engagement should take place through our customers. In line with IFC Performance Standards, FMO aims to empower both communities and customers to do so.

  • Our draft position statement on phasing out fossil fuels from direct investments that was open for consultation. Feedback was generally positive and gives us confidence that we are moving in the right direction. We are currently processing this feedback.

Dutch Banks

FMO was a signatory of the Dutch Banking Sector Agreement on international responsible business conduct regarding human rights, which focused on the implementation of the OECD Guidelines for Multinational Enterprises and the UNGPs. This covenant formed an agreement between a coalition of banks, the Dutch Banking Association (NVB), trade unions, civil society organizations, and the Dutch Government that was operational until the end of 2019. Since then, an independent committee has been monitoring the progress made by the adhering banks. FMO remains committed to improving its standards and continues to collaborate with other Covenant parties. In 2020, FMO completed the self-assessment for the final report of the independent committee. Furthermore, it collaborated with the NVB and other Dutch banks to follow up on the Dutch Banking Sector Agreement. An outcome of these discussions led to a letter from the NVB, on behalf of all Dutch banks, to the Dutch Parliament to communicate its support towards introducing new legislation on mandatory due diligence in the EU.

Development Finance Institutions & Knowledge Partners

Partner development finance institutions and multilateral development banks co-finance with us and deliver valuable local knowledge about the markets in which we operate. We share knowledge with our peers and work on harmonizing impact measurement and ESG. FMO plays a leading role in EDFI's Harmonization Initiative. In 2020, EDFI's focus was on developing a joint response to the COVID-19 pandemic in support of our customers. An example of this effort was the EDFI joint approach to debt payment deferrals.

We also continue to engage and learn from other knowledge partners including universities, NGOs, and independent consultants. Each year, FMO commissions studies that assess the impact of our products and services. We established an Independent Advisory Evaluation Panel, consisting of academic and other specialists in the field of evaluation, to help us safeguard the quality and effectiveness of these studies. The Panel convenes every quarter with FMO’s evaluation specialists, investment staff and independent consultants to critically assess the set-up, progress, conclusions and recommendations of external studies.

In the agri-food domain, we partner with the UN Food and Agriculture Organization (FAO) which has enabled us to connect knowledge and innovation to market opportunities for more impact. In 2020, FMO partnered with FAO to support the growth of agricultural SME finance in Kenya.