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/or 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, 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 new ICM Policy is being revised. The policy revision process started in 2024 and the proposed new version was publicly consulted from mid-August to mid-October 2025. In addition to webinars held across different time zones, two in-person events were organized in The Hague and in Nairobi. The final version of the policy, following the review of public feedback, is expected to be published early 2026 and to enter into force by March 1, 2026.

Additionally, due to an Independent Expert Panel Member reaching the end of her five-year term in April 2026, a vacancy for the position was published on November 2, 2025 via the DFIs’ websites and LinkedIn. FMO is leading the recruitment on behalf of the participating institutions.

The Ministry of Foreign Affairs periodically carries out an independent 'FMO-A evaluation', which includes the ICM. The 2025 evaluation is underway and scheduled for completion in early 2026.

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