Mechanism World Bank Inspection Panel World Bank Compliance Advisor Ombudsman European Investment Bank Complaint Mechanism And The European Ombudsman European Bank For Reconstruction And Development’s Independent Project Accountability Mechanism (IPAM) Inter-American Development Bank Independent Consultation And Investigation Mechanism African Development Bank - Independent Review Mechanism (IRM) Asian Development Bank Office Of Special Project Facilitator (OSPF) And Accountability Mechanism (Special Project Facilitator (SPF) And Compliance Review Panel (CRP))
Financial Institutions’ members International Bank for Reconstruction and Development (IBRD)

International Development Association (IDA)

International Finance Corporation (IFC)

Multilateral Investment Guarantee Agency (MIGA)

European Investment Bank (EIB) European Bank for Reconstruction and Development (EBRD) Inter-American Development Bank (IADB)

Inter-American Investment Corporation (IIC)

Multilateral Investment Fund (MIF)

African Development Bank (AfDB) Asian Development Bank (ADB)
Parties permitted to submit a request - A community of persons (not an individual) living in the territory of the borrower State and believing they are suffering or may suffer harm from a WB-funded project, that the WB may have violated its operational policies or procedures with respect to the project, and that the violation is causing the harm.

- Another person if provide documentation authorizing them as representatives who represents the complainant;
  - a local NGO

  - a foreign NGO, but only where local representation is not available

- Any individual, group, or community directly impacted or likely to be impacted by social or environmental impacts of an IFC or MIGA project.

- Representatives of an affected group may submit a complaint on their behalf if they provide their names and authorisation of representation.

- Any natural or legal person affected, or feeling affected, by a decision of the EIB which relates to maladministration of EIB group in its action or omission.

- For the European Ombudsman: EU citizens or a person residing or having its registered office in an EU country (at possibly non-EU nationals at the discretion of the Ombudsman, non-EU nationals)

- In case of Problem solving Initiative: one or more individual(s), located in an impacted area, or who has or have an economic interest in an impacted area.

- In case of Compliance Review: one or more individual(s) or organisation(s) (including an NGO if it is registered in a member country of the Bank) in relation to a project that has been approved for financing

- One or more persons, groups, associations, entities or organisations whose rights or interests have been or are likely to be directly and materially adversely affected by an action or omission of the Bank as a result of a failure of the Bank to follow its policies.

- Authorized representative

- Any group of two or more persons or organisations, associations in the country or countries where the Bank Group-financed project is located who believe that as a result of the Bank Group’s violation of its policies and/or procedures, their rights or interests have been, or are likely to be, adversely affected in a direct and material way or;

- A duly appointed local representative.

- Foreign representation is allowed only when local representation cannot be found. The Boards of Directors can also refer a project to IRM to conduct a compliance review

- Any group of two or more persons (such as an organisation) in a borrowing country where an ADB-assisted project is located or in a member country adjacent to the borrowing country, or a local representative of the affected group; and believing they are or are likely to be, directly affected materially and adversely by an ADB-assisted project

- local authorized representative

- non-local representative only where local representation is not available

Subject of the complaints Non-compliance with WB policies or procedures, including environmental assessment, indigenous peoples and involuntary resettlement; and current or future harm stemming from a project with at least some funding from the World Bank’s IBRD or IDA. Non-compliance with IFC and MIGA Performance Standards including social and environmental assessment, labour and working conditions, land acquisition and involuntary resettlement, biodiversity conservation, indigenous peoples.

These operational policies are undergoing a review process that should be finalised in early 2015."

Non-compliance with EIB’ standards, including environmental and social standards, consultation, participation and disclosure standards as well as standards related to indigenous peoples, climate change and cultural heritage; and non-compliance to Applicable law, Internationally recognized human rights, or Principles of good administration. Non-compliance with EBRD’s Environmental and Social Policy (2014) and the bank principles such as environmental sustainability, health, safety and community issues and compliance with applicable regulatory requirements and good international practice. Non-compliance with the IDB’s Relevant Operational Policies, including environmental safeguards, gender policies and information disclosure policies. Violation of policies/ procedures including non-compliance with its environmental and social impact, poverty reduction, gender, integrated Water Resources Management; and involuntary resettlement. Non compliance with ADB procedures and policies including the Safeguard Policy Statement (including on Environment, Involuntary Resettlement and Indigenous Peoples) and the Sector Policy Papers (including Energy, Forestry and Water).
Time limits for complaints Complaints must be submitted before the project is closed and before 95 percent of the funding has been disbursed. Complaints may also be submitted before the Bank has approved financing for the project or program. Not stated time limit Within one year from the date after which the respondent could be in a position to acknowledge the facts upon which the allegation is grounded. For Problem-Solving Initiative: 12months from last disbursment. For Compliance Review: no more than 24 months after the date on which the EBRD ceased to participate in the project. Within 24 months after the last disbursement of funds by the Bank. Up to a year after the final disbursement of the loan or physical completion of the project. Up to two years after the loan or grant closing date.
Type of mechanism and outcome The Panel decides whether to recommend an investigation. If it decides so, the Panel will complete an investigation and issue a report of their findings.

The Bank Management is required to respond and to indicate how it will address the findings with an action plan. The Board makes a final decision which is made public.

The CAO will investigate the complaint and will determine how to move forward.

For Dispute Resolution the CAO will facilitate a process designed to address the issues in the complaint with the goal of reaching a mutually agreeable solution. For Compliance the CAO conducts an appraisal and may conduct a full compliance investigation. Compliance investigation reports are made public, and the CAO monitors changes until the IFC/ MIGA take steps to resolve noncompliance.

If the complaint is eligible, the Office will conduct an investigation using a flexible approach, which may include compliance review and/ or problem-solving. The Office concludes its work by issuing recommended corrective actions in its Conclusions Report.

The complainant can appeal the EIB Complaints conclusions or ask for a follow up on implementation of EIB conclusions by submitting a confirmatory complaint. He/she can also turn to the European Ombudsman if the complainant is not satisfied with the EIB process.

- In case of Problem solving Initiative: the aim is to restore dialogue between the complainant and the client. If an agreement is reached, IPAM will conduct any necessary monitoring.

- In case of Compliance Review: the aim is to determine if the ERBD has complied with its policies.

Possible outcomes include a report with recommendations for corrective action. IPAM can also monitor changes arising from the compliance review process.

In Consultation Phase, MICI conducts an assessment and facilitates dialogue between the parties. If an agreement is reached, MICI monitors its implementation.

In Compliance Review Phase, MICI investigates whether the IDB failed to comply with its policies and thereby harmed complainants. MICI presents its report to the Board, which determines what action to take, including whether Management should develop an Action Plan to address any noncompliance. The report is released to the public along with the Board’s decision. MICI will monitor implementation of the Action Plan or other agreed remedial actions.

After examination of the complaint, the Unit will decide if it is more efficient to conduct a problem-solving process and/or a compliance review. The panel submits a report to be approved by the President or the Board and which includes findings and recommendations, as well as a designated person to monitor the implementation of proposed changes. The Complaints Receiving Officer forwards complaint to the Problem Solving or Compliance Review functions.

In Problem Solving, the SPF attempts to facilitate an agreement between the parties involved, and monitors the implementation of this agreement.

In Compliance Review, the CRP conducts an investigation into whether the ADB has complied with its policies and procedures. The CRP presents its findings to the ADB Board, which decides whether to take action.

Extracts from: Accountability Resource Guide, Tools for Redressing Human Rights & Environmental abuse in International Finance and Development, Accountability Counsel, 8th edition, August 2015, op cited.
Human Rights & Grievance Mechanisms Brochures, SOMO and Accountability Counsel, op cited.