Independent complaints mechanism

FMO invests in emerging markets and developing economies and aims to create value for the organization, its stakeholders, society, and the environment. When investments lead to environmental and human rights harm, FMO is accountable to affected communities through its independent accountability mechanism. FMO has implemented an Independent Complaints Mechanism (ICM) together with the Deutsche Investitions- und Entwicklungsgesellschaft (DEG) and the French DFI Proparco. This allows people who feel affected by an FMO-financed operation to file a complaint with an independent expert panel. The independent expert panel is part of the ICM and has a dual mandate: a fact-finding and monitoring role (compliance review) and a problem-solving role (dispute resolution). Escalating to the problem-solving role is only possible if all parties agree and there is a reasonable expectation that a mutually-agreed resolution of the complaint will be possible.

The Independent Expert Panel prepares reports in several phases of a complaint (e.g. notice of admissibility, preliminary review, compliance review, dispute resolution process, monitoring report) as specified in ICM’s policy. Before publicly publishing on FMO’s website on Complaints disclosure (new window), parties (complainant, client, FMO) are asked for comments to ensure adequate reflection of facts and sensitivities. These reports can be used to monitor the complaints’ progress and outcomes of the process. 

The ICM applies an approach of continuous improvement. In the ICM annual report the overall effectiveness of the mechanism is (publicly) reported. In addition, peer complaint mechanism best practices are followed to continuously improve the mechanism. Procedures are developed and/or adjusted on this basis. Furthermore, the ICM and its policy must be evaluated at least every four years. Currently, the update of the policy is in progress following an external evaluation. The policy update process includes a round of public consultation to ensure that stakeholders can provide their comments, which will be considered in the finalization of the new ICM policy. In addition, the Ministry of Foreign Affairs periodically has an independent 'FMO-A evaluation' carried out, of which the ICM is a part. This was last done in 2020.

For more information, please see the Independent complaints mechanism on FMO’s website.