The Independent Complaints Mechanism
Established in 2014, the Independent Complaints Mechanism (ICM) is a joint initiative of the participating Development Finance Institutions – namely DEG (Deutsche Investitions- und Entwicklungsgesellschaft), FMO (Nederlandse Financierings-Maatschappij voor Ontwikkelingslanden N.V.) and Proparco (Société de Promotion et de Participation pour la Coopération Économique, SA).
The DFIs are committed to achieve positive sustainable development outcomes through their investments. At the same time, the DFIs recognize that such development can also have a negative impact on local communities and the environment.
The ICM Policy Review & Update
The DFIs are committed to regularly reviewing and, where necessary, updating the ICM Policy to ensure it stays robust, effective, accessible, and properly structured to guide the complaints process, while serving the needs of stakeholders as intended.
In 2022, the Management Boards of the DFIs started the review process by commissioning a report from an independent expert. The purpose of the report was to advise the DFIs on key policy gaps, issues and opportunities and to build consensus among the three DFIs around areas of policy revision.
The Policy Review report made broad-based recommendations for change in light of accepted good international practice and key stakeholder concerns and interests. It included a document review, DFI peer benchmarking, and stakeholder interviews.
The Policy Review report was finalized in 2023 and, based on its recommendations, the Policy Update process commenced in 2024.
The ICM Public Consultation
The ICM Public Consultation on the Draft ICM Policy began on Wednesday 20 August 2025 and concluded on Friday 17 October 2025.
The ICM Public Consultation was an essential part of the ICM Policy Review & Update process and ensured that stakeholders had an opportunity to submit their input and comment, ask questions and participate in discussions on the Draft ICM Policy, prior to the DFIs finalizing and adopting a final policy.
This website is the main portal for information about the Draft ICM Policy and the ICM Public Consultation: including the purpose and objectives of the consultation; who and how the consultation was managed; and the next steps now the consultation has concluded, including public reporting of consultation findings.
The Draft ICM Policy
The Draft ICM Policy has been prepared by a joint working group consisting of the Independent Expert Panel that form part of the ICM, and representatives from the DFIs as part of the ICM Policy Review & Update process, and has been approved for public consultation by the Management Boards of the DFIs.
It is being disclosed to stakeholders during the ICM Public Consultation for their input and comment prior to finalizing and adopting a final policy. It is important to note that the draft is not a final policy and is subject to further change based on input received during the public consultation and as part of the final approval of the policy by the Boards of the DFIs.
The Draft ICM Policy is available for review here.
Public Consultation Reporting & Policy Finalization
The findings of the ICM Public Consultation will be collated, summarized, and published on this website, and on the respective DFI web pages, in the weeks following the end of the consultation period.
The joint working group responsible for drafting the Draft ICM Policy (i.e. the ICM Independent Expert Panel and representatives from each DFI) will again engage in a collaborative process, facilitated by an independent external consultant, to consider the findings and prepare a final version of the ICM Policy.
The final version of the ICM Policy will be approved by the Boards of the DFIs in December 2025 /early January 2026, and will become effective on a date to be agreed by the institutions (but expected within the first quarter of 2026).
Frequently Asked Questions
This page offers responses to general questions on the ICM, the ICM Policy Review & Update process, and the ICM Public Consultation.