The Independent Complaints Mechanism
Established in 2014, the Independent Complaints Mechanism (ICM) is a joint initiative of the participating Development Finance Institutions (DFIs):
- DEG (Deutsche Investitions-und Entwicklungsgesellschaft)
- FMO (Nederlandse Financierings-Maatschappij voor Ontwikkelingslanden N.V.)
- Proparco (Société de Promotion et de Participation pour la Coopération Économique, SA)
The DFIs
DEG, FMO and Proparco are leading European Development Finance Institutions (the DFIs) with a common mission to promote private investments that foster sustainable development in emerging markets by financing sustainable private investments.
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 DFIs pursue environmental and social sustainability by applying their respective policies on environmental and social sustainability. Nevertheless, during the course of an investment, projects may have adverse impacts on the environment and people, including communities, workers or others.
The ICM
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 aims to provide predictable, transparent and equitable processes through which complainants can raise their concerns, and through which complaints may be resolved.
a) Through its dispute resolution function, the ICM uses mediation and facilitation to address concerns of complainants, by engaging the complainant, the client and other parties in collaborative processes.
b) Through its compliance function, the ICM determines whether a DFI’s non-compliance with its environmental and social policies is connected to harm, recommends ways to address non-compliance and related harm, and draws lessons for current and future DFI Financed Operations.
The ICM also provides advice to the DFIs based on its experience and related international good practice and undertakes outreach activities to raise awareness of the ICM.
The effectiveness of the mechanism depends on a robust and appropriately framed policy to inform and guide its activities. This requires regular review and, where necessary, updating of the ICM policy.
Further information on the current review can be found at ICM Policy Review & Update.
For further information on the ICM, the Independent Expert Panel, the current ICM Policy (dated 2017), and how to submit a complaint, please visit the respective DFI websites: