The ICM Public Consultation
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. A summary report on the ICM Public Consultation activities is available for download here: ICM Public Consultation Activity Report.
The joint working group — comprising the ICM Independent Expert Panel and DFI representatives — has continued its collaborative process to review all stakeholder feedback and finalize the ICM Policy. The policy will be finalized following approval by the Management Boards and endorsement by the Supervisory Boards of the DFIs, anticipated in December 2025. A formal response to stakeholders will be published with the final ICM Policy and it will detail how feedback has been considered and integrated. The updated ICM Policy is expected to come into effect in the first quarter of 2026, with further details provided with the formal response.
The Independent Complaints Mechanism
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.
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 ICM ensures the right to be heard for complainants who believe that they have been or may be adversely impacted by DFI financed operations.
The 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.