Environmental and Social Independant Complaints Mechanism (ICM)

ICM

Proparco set an Independent Complaints Mechanism where individuals, groups, communities or other parties who believe to be adversely affected by a project financed or planned by Proparco can make a complaint and will be heard by independent experts.
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Individuals, groups, communities or other parties who believe to be adversely affected by a project financed or planned by Proparco can make a complaint and will be heard by independent experts.
The Independent Complaints Mechanism is a joint initiative with DEG - Deutsche Investitions und Entwicklungsgesellschaft and FMO - Netherlands Development Finance Company.

The Independent Complaints Mechanism

Proparco's purpose is to promote private enterprise initiative in developing and emerging countries as a contribution to sustainable growth and a lasting improvement in the living conditions of the local population. In order to achieve sustainable progress, Proparco sets high standards for its own business as well as for its clients. Nevertheless, during the course of investment, projects might have unexpected or unmitigated adverse impacts.
To ensure individuals, groups, communities or other parties who believe to be adversely affected by a project financed or planned by Proparco the right to be heard and the right to complain, Proparco set an Independent Complaints Mechanism (hereafter also: the ‘Mechanism’ or ‘ICM’).

The Mechanism provides stakeholders with a tool to seek alternative ways to resolve disputes between stakeholders and Proparco’s clients. At the same time the Mechanism strengthens the implementation of and adherence to Proparco’s own policies and procedures even further by providing a feed-back loop for Proparco.

The Independent Complaints Mechanism consists of an Independent Expert Panel (hereafter also: the ‘Panel’ or ‘IEP’) that is supported by Proparco’s Complaints Office. The Independent Expert Panel consists of a group of three persons with environmental, social, legal and financial expertise. The Panel is fully independent of Proparco. It decides whether a complaint is admissible, responds to the complainant, is responsible for a dispute resolution or a compliance review and reports on individual complaints. The Complaints Office is a function performed by Proparco employees, which registers and acknowledges receipt of complaints, coordinates adequate fulfillment of the complaints process and provides practical support to the Panel.

The Mechanism is a joint initiative with DEG - Deutsche Investitions und Entwicklungsgesellschaft  and FMO - Netherlands Development Finance Company.
 

How it works?

The goal of the Mechanism is to address specific issues that have contributed to a conflict and help stakeholders identify solutions that meet the interests of all the parties.

Who can make a complaint?

Any individual, group, community, or other party can make a complaint if they believe they are, or may be, negatively affected by a project financed or planned by Proparco.

Complaints may be presented through a representative party, when the persons on whose behalf the representative is acting are identified and evidence of the representative’s authority to do so is provided in the complaint.

Complaints can be submitted in any official language, although English is preferred.

Processing of complaints not submitted in English may require additional response time due to the need for translation. The Complaints Office and/or Panel will timely notify the complainant of any delays required for translation.

What are the criteria for making a complaint?

The following eligibility criteria have to be met for a complaint to qualify for assessment:

  • Complaint relates to a project financed by Proparco.
  • Complaint contains allegations with material adverse impacts or risks.
  • There must be a relationship between the project and the alleged impacts.
  • Complainant believes they are, or may be, affected by the issues raised.
What types of complaints are not accepted?

Inadmissible complaints are those

  • that do not meet the eligibility criteria,
  • concerning criminal offences or breaches of the French Law or similar irregularities, which are dealt with by Proparco Compliance or the confidential whistleblower system ,
  • concerning procurement decisions,
  • from anonymous parties,
  • that are excessive, repetitive, clearly frivolous or malicious in nature.
Can confidentiality be requested?

If requested, Proparco will not reveal the identity of the complainants to the project sponsor and will jointly agree with the complainants on the process for handling the complaint.

In addition, materials submitted by complainants on a confidential basis will not be released without their consent.

Parties will be advised by Proparco if confidentiality may constrain efforts to seek a satisfactory resolution.

Is the Mechanism applicable to all projects financed by Proparco?

In February 2019, Proparco commenced introducing the necessary contractual arrangements to include the Mechanism’s procedures in its financing and investment agreements with clients.

If a Complaint relates to a case in which the necessary contractual arrangements are missing, the full implementation of the Mechanism’s procedures will require the cooperation of all relevant parties.

This includes, but is not limited to, allowing non-public information relating to the case at hand being shared with the persons involved in the Mechanism.

The process of handling the Complaint may consequently require more time in order to establish and maintain the necessary cooperation, and the possibilities to process the Complaint in accordance with the procedures set out in the Mechanism may be restricted. In the event that the Complaint requires an approach which deviates from the Mechanism’s procedures, the Complainants will be informed on a regular basis on the approach and the process that will be followed.

How and where to file a complaint?

The following sub-page How to file a complaint  explains how and where people who believe they are negatively impacted by a Proparco -financed project can file a complaint. The preferred language is English. Processing of complaints not submitted in English may require additional response time due to the need for translation. The Complaints Office and/or Panel will timely notify the complainant of any delays required for translation.

What happens when a complaint is filed?

Proparco will acknowledge receipt of the complaint within 5 working days (Paris). Your complaint will be forwarded to our Independent Expert Panel, which will decide on the eligibility of your complaint If your complaint is deemed ineligible you will be notified and informed of the reasons. The Independent Expert Panel will attempt to make recommendations on other possibilities open to you.

How does the complaint handling process work?

If the complaint is eligible, the Independent Expert Panel will conduct an assessment to get a better idea of the situation and different points of view. With the information gathered, they will decide about the further process steps: a dispute resolution process or a compliance review.
In the case of a dispute resolution process, the Panel member will work with you and the project sponsor to develop a process appropriate for addressing the issues raised in the complaint. This may include information sharing, facilitated discussions or mediation with the aim of finding a solution that is acceptable for both sides. The Independent Expert Panel does not take a position on whether any allegations are accurate nor does it find fault or impose solutions.
In a compliance review the Panel will investigate whether the project was financed in conformance with the compliance investigation criteria / relevant policies  .
In particular cases both processes may be combined.

How to file a complaint?

Complaints must be submitted in text form. Complaints can be submitted via internet, by e-mail or per mail/post. Please ensure that your complaint includes the following:

  • Name and contact details, including country of residence*
  • Proof of authority to represent if filing is done by a representative
  • Identification of the Proparco -financed project (e.g. company name and project site) that is linked to the alleged adverse impact*
  • Information regarding the alleged harm, provided in as much detail as possible, and how you are directly affected*. If you have any documents you deem relevant, please attach these to your complaint
  • Information what has been done prior to this complaint to address the stated harm*
  • Whether you wish that Proparco keeps your complaint confidential*
  • If relevant, provide an indication, which of Proparco’s policies has allegedly been breached
  • What you hope to achieve with your complaint, what resolution or remedy you are seeking*

Information marked * is mandatory.

Via internet:
You may submit the complaint by means of our secure online form.
Online form 

By mail/post:
Please send your complaint, preferably using the complaint template provided, to the following address:
Complaints Office
Proparco 
151 rue Saint Honoré 
75001 Paris
France

 

By email:
Please send your complaint, preferably using the complaint template provided, to the following email address: complaintsoffice@proparco.fr.
 

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