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 can be held accountable to affected communities through its independent accountability mechanism. FMO has implemented an Independent Complaints Mechanism (ICM) together with the German DFI, Deutsche Investitions- und Entwicklungsgesellschaft (DEG), and French DFI, Proparco. The ICM 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'). Utilizing 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 the ICM’s policy. Before publicly publishing the complaints disclosure on FMO’s website, the parties (complainant, customer and FMO) are asked for comments to ensure adequate reflection of the facts and any sensitivities. These reports can be used to monitor the complaint’s progress and outcomes.

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 good practices are considered to achieve improvements. Procedures are then developed and/or adjusted accordingly. The ICM and its policy are also evaluated at least every four years. Based on the evaluation performed in 2022-2023, the ICM policy is currently being revised. The policy revision process includes a round of public consultation to ensure stakeholders are able to provide their input, which will be considered when finalizing the new ICM policy, which is expected in 2025. In addition, the Ministry of Foreign Affairs periodically carries out an independent 'FMO-A evaluation', which includes the ICM. The next ‘FMO-A evaluation’ is planned for 2025. 

For more information, please refer to the Independent Complaints Mechanism on FMO’s website.