Environmental and Social Independant Complaints Mechanism (ICM)

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 managed 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.

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

• Complaint relates to a project financed or managed 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.

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.

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.

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.

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.

• 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 or managed  in conformance with the compliance investigation criteria / relevant policies. In particular cases both processes may be combined.

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 related 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.

Submit a complaint

The information collected about you is processed under the responsibility of Proparco in order to manage the E& S complaints mechanism. You can, under the conditions defined by the applicable regulations, access your personal data or request their erasure. You also have the right to object, the right to rectification, the right to restrict the processing of your data and the right to data portability. To exercise these rights or if you have any questions about the processing of your data, you can contact the Data Protection Officer (DPO) of the AFD group, electronically: informatique.libertes@afd.fr or via an online form. If you feel, after contacting the DPO and getting its response, that your rights are not being respected, you can make a complaint to the CNIL.

More information on the processing of the collected data