Frequently Asked Questions
This section offers responses to frequently asked questions on the ICM, the ICM Policy Review & Update Process, and the ICM Public Consultation.
Introduction to the ICM
What is the Independent Complaints Mechanism?
Established in 2014, the Independent Complaints Mechanism (ICM) is a joint initiative of the participating Development Finance Institutions – DEG, FMO and Proparco. As leading European DFIs, they are committed to fostering sustainable economic growth in developing and emerging markets by financing sustainable private investments.
What is 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. The ICM Policy Review & Update is the current process to review and update the ICM Policy.
What is the ICM Public Consultation?
The DFIs provided a formal and independent ICM Public Consultation to present the Draft ICM Policy and give stakeholders the opportunity to submit input and comments, ask questions, and participate in discussions on what is important to them.
The ICM Public Consultation began on Wednesday 20 August 2025 and concluded on Friday 17 October 2025.
Policy & Stakeholders
What is the Draft ICM Policy?
The Draft ICM Policy was 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 was approved for public consultation by the Management Boards of the DFIs. It was shared with stakeholders during the ICM Public Consultation for their input and comments prior to finalizing and adopting a final policy.
Who could submit input and comments on the Draft ICM Policy?
The DFIs welcomed input and comments from any stakeholders and there was interest from a variety of stakeholders including:
- project-affected individuals, communities, and related groups;
- Community Based Organizations (CBOs);
- international, regional, and national Civil Society Organizations (CSOs) and Non-Governmental Organizations (NGOs);
- DFI clients and customers;
- government departments and inter-governmental organizations and initiatives;
- peer financial institutions;
- other Independent Accountability Mechanisms (IAMs);
- academics, subject-matter and legal experts in environmental, social, human rights and accountability mechanisms; and
- the general public.
Management & Communications
How was the ICM Public Consultation managed?
An independent and external consultant was appointed as ‘ICM Public Consultation Coordinator’ to manage and deliver the ICM Public Consultation on behalf of the DFIs.
The Public Consultation Coordinator had a variety of responsibilities including, but not limited to:
- being the first point of contact for all stakeholder enquiries;
- providing the framework for stakeholder engagement (e.g. hosting and managing the ICM Public Consultation website and webinars, providing coordination support to consultation meetings); and
- collecting, storing and managing stakeholder contact, webinar registration, and comment submission data.
The ICM Public Consultation Coordinator role was fulfilled by Samantha Dierckx, Founder of the UK based company ‘The Greater Good Consulting Company’.
How can stakeholders contact the ICM Public Consultation?
Stakeholders can contact the ICM Public Consultation Coordinator on public consultation matters on email at info@icm-consultation.org or via the Contact page.
How are we safeguarding stakeholder’s personal data, input and comments, and confidentiality?
Stakeholder data protection and privacy is important to us, and we take their confidentiality very seriously, therefore this answer is quite long.
General
The ICM Public Consultation Coordinator is the owner and manager of the ICM Public Consultation website and associated email accounts – info@, register@ and comment@ – and therefore legally responsible for all data and privacy matters.
In all communication, stakeholders will be made aware of their rights to privacy and confidentiality, and will have the option to withdraw consent, or opt out, wherever and whenever they are asked to submit personal data.
Any personal data (e.g. name, place of work, affiliation, job title, department, location, contact details) collected is protected by the UK and EU General Data Protection Regulation (GDPR) legal frameworks that sets guidelines for the collection and processing of personal information from individuals.
This means that personal data will not be shared with the DFIs, or any external parties, for any purpose unless consent is explicitly given by the submitter. Furthermore, stakeholders may request that their personal data is deleted at any time.
Website Browsing
The ICM Public Consultation Coordinator is the primary recipient of information automatically collected from website visitors (e.g. IP Address, web browser type and version) and any information submitted by stakeholders via an online form (e.g. webinar registration, consultation surveys, input and comment submissions).
On first visit, visitors will be invited to review the website’s Privacy Policy and select their ‘Privacy Preferences’.
Emails
The ICM Public Consultation Coordinator is the primary recipient of emails (and any associated attachments) to the public consultation email accounts. Emails received will not be forwarded on to any third party – including the DFIs – without the consent of the Sender.
Any emails that appear to be forwarded from another Sender will be source checked and, if not stated clearly by the original Sender, permission will be requested to process their personal data and/or use the information contained in their original email and any associated attachments.
If a Sender requires specific confidentiality considerations or handling, they should make it clear in their email subject line or body.
Webinars & Meetings
When stakeholders register for a public consultation webinar or meeting, they will be asked to give consent for their personal data to be collected and shared with the organizer for security purposes and host/presenters to support participation.
Whilst the ICM Public Consultation Coordinator will remind participants of confidentiality considerations at the start and end of webinars or meetings, they are not responsible for any disclosures made by participants.
Input & Comments
Where stakeholders provide input or comments (verbally or in writing) on the Draft ICM Policy, attribution to an individual or organization will automatically be removed prior to sharing input and comments internally or including it in any public consultation reporting.
The ICM Public Consultation Coordinator will share general demographic information with the DFIs to support their understanding of the stakeholder’s input or comment. For example, information may be shared on stakeholder type (e.g. affected community, NGO, government or client) and/or country and/or regional location (e.g. the United Kingdom, Asia).
It is understood that some stakeholders may disclose their input or comments on their own website or social media platforms.
Will stakeholders receive a response to their questions and/or their input and comments on the Draft ICM Policy?
The ICM Public Consultation Coordinator will endeavour to answer any and all questions submitted by stakeholders, however the following considerations and limitations apply.
Subject Matter
The ICM Public Consultation Coordinator cannot respond to:
- specific or technical questions on the current ICM Policy or on the Draft ICM Policy, unless it is a matter of understanding the ‘English’ language.
- any questions or comments on DFI project or investment related matters.
- ICM complainants, or their representatives, on new, existing or past complaints.
Response Time
Enquiries and input and comments will be acknowledged, and as appropriate responded to, during the working week only (Monday to Friday 9am-6pm UK Time) and typically within 72 hours of receipt. Emails received on a Friday, or where a UK Public Holiday follows a weekend, will be responded to at the earliest on the following Monday or Tuesday respectively. If an enquiry is of a complex nature or submitted in another language, a longer response time may be required. If a matter is for urgent attention, the stakeholder should indicate in the ‘Subject Line’.
Language
The official language of the ICM Public Consultation is English and all responses will be provided in English. However, stakeholders can make their enquiries and/or submit their input and comments on the Draft ICM Policy in another language. The ICM Public Consultation Coordinator cannot guarantee that enquiries and/or comments submitted in another language will be understood exactly as intended once translated in to English.
Post Consultation
What will happen to stakeholder input and comments on the Draft ICM Policy after submission?
The input and comments submitted by stakeholders 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. It should be noted that attribution to an individual or organization will automatically be removed prior to sharing input and comments internally or including it in any public consultation reporting.
The joint working group responsible for drafting the Draft ICM Policy (i.e. the ICM Independent Expert Panel and representatives from the DFIs) 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.
Will input and comments on the Draft ICM Policy be made publicly available?
Yes, the intention is to disclose a summary of the findings and publish it on this website, and on the respective DFI web pages, in the weeks following the end of the consultation period.
It should be noted that attribution to an individual or organization will automatically be removed prior to sharing input and comments internally or including it in any public consultation reporting.
When will a final updated ICM Policy be available?
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).