Revised ICM Policy – Effective from 1 March 2026
The Development Finance Institutions (DFIs)—DEG, FMO, and Proparco — aim to achieve sustainable development by applying its environmental and social policies in its investments. Nevertheless, during the course of an investment, projects may have adverse impacts on the environment and on people, including communities, workers, and other affected stakeholders. The Independent Complaints Mechanism (ICM) ensures the right to be heard for complainants who believe they have been, or may be, adversely impacted by our financed operations, and it seeks to address harms that may have occurred. The ICM is a joint initiative of DEG, FMO, and Proparco (DFIs). The DFIs are committed to regularly reviewing and, where necessary, updating the ICM Policy to ensure it remains robust, effective, aligned with good practices, accessible, and properly structured to guide the complaints process, while serving the needs of stakeholders as intended.
The DFIs and the Independent Expert Panel (the “Panel”) led a multi‑year, expert‑facilitated, and consultation‑driven revision of the ICM Policy, working collaboratively from the initial 2022 review through extensive stakeholder engagement and consensus‑oriented drafting. Following a formal public consultation process in 2025, the jointly prepared final ICM Policy was endorsed or acknowledged by the DFIs in December 2025.
The final ICM Policy came in to effect as of 1 March 2026, after which all newly submitted complaints will be handled under the updated policy. With this transition, the DFIs are also introducing a Panel Chair role. The DFIs are pleased to announce that Dr. Marina d’Engelbronner-Kolff, a current Panel Member, has been appointed as the Panel Chair.
The DFI’s respective announcements on the revised ICM Policy are available at:
Post-ICM Public Consultation Reports
The Development Finance Institutions (DFIs)—DEG, FMO, and Proparco — and the ICM Independent Expert Panel, wish to express their sincere appreciation to all internal and external stakeholders who participated in and supported the ICM Public Consultation on the Draft ICM Policy, held from 20 August to 17 October 2025.
During the 8.5-week consultation period, a diverse range of stakeholders — including national and international non-governmental and civil society organizations, peer financial institutions, independent accountability mechanisms, DFI clients, and subject matter experts — provided substantive feedback on the Draft ICM Policy.
Feedback was received in writing through 15 formal submissions representing 34 unique organizations and individuals, and verbally through a series of regional webinars and in-person meetings attended by over 50 individuals representing all key stakeholder groups and geographies.
The following post-ICM Public Consultation reports are available:
- A summary report on the activities that took place during the ICM Public Consultation: ICM Public Consultation Activity Report.
- A summary report on stakeholder feedback received during the ICM Public Consultation: ICM Public Consultation Stakeholder Feedback Report.
ICM Policy Review & Update
The DFIs are committed to regularly reviewing and, where necessary, updating the ICM Policy to ensure it remains robust, effective, accessible, and properly structured to guide the complaints process, while serving the needs of stakeholders as intended.
In 2022, the DFI Management Boards launched the ICM Policy Review process and appointed an independent expert to conduct a high-level review of the ICM Policy—including document analysis, peer benchmarking, and stakeholder interviews— and produce a report identifying key policy gaps, issues, and opportunities. The report also helped build consensus among the DFIs on the priority policy areas for revision. The Policy Review Report was finalized in 2023 and made broad recommendations in line with accepted good international practice and in response to stakeholder concerns and interests.
The ICM Policy Update Process was initiated in 2024, during which the DFIs consulted a select group of external stakeholders—including non-governmental organizations and subject-matter experts—on the ICM Policy. Subsequently, a joint working group —comprising the ICM Panel and DFI representatives— was established to reflect on stakeholder feedback, consider the recommendations of the Policy Review Report, and begin preparing the Draft ICM Policy.