New Step in FMO’s Complaint Policy – Civil Society Organizations Call for Further Strengthening
The updated complaint mechanism of the development banks FMO, DEG, and Proparco marks an important step forward. Organizations that participated in the consultation acknowledge the efforts to improve the mechanism. At the same time, they emphasize that much still needs to be done to make the policy truly effective, transparent, and independent.
Why a Strong Complaint Mechanism Is Crucial Now
Pressure on civil society organizations, communities, and individuals is increasing worldwide. In more and more countries, fundamental freedoms are being restricted. People who raise concerns or speak out against misconduct face intimidation, repression, or even violence.
At the same time, support for civil society is declining, making it increasingly difficult to represent affected communities. In this context, it is essential that development banks—institutions responsible for fair and sustainable development—have accessible, independent, and well-functioning complaint mechanisms.
Both ENDS, together with partner organizations that have supported communities negatively affected by FMO investments for years, has provided recommendations to further improve the policy.
Recommendations: Progress Made, but Major Shortcomings Remain
Although the new policy has improved in several areas, important weaknesses remain. Significant steps are still needed in terms of transparency, independence, protection against retaliation, and institutional capacity.
Key Areas for Improvement
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More transparency about financial intermediaries (FIs):
Despite improved wording, it remains unclear how FMO’s relationships with FIs are structured and which subprojects fall under them. Without transparency, communities often do not even know whether they are eligible to file a complaint. As long as FMO does not disclose its FI investments, the complaint mechanism remains inaccessible to the people it is meant to protect. -
Clear reference to international standards:
The policy does not clearly state which international norms complaints may refer to. FMO should explicitly acknowledge that complaints can be based on the IFC Performance Standards, OECD Guidelines, UN Guiding Principles, and EDFI principles, as agreed upon with the Dutch government. This would provide clarity to communities considering filing a complaint. -
Strengthen independence and governance:
The current governance structure provides insufficient safeguards for independent oversight. As long as the complaint mechanism lacks its own mandate to initiate investigations, it remains dependent on the very institution it is supposed to hold accountable. -
Stronger protection against reprisals:
Although FMO recognizes the importance of protection against retaliation, the current measures are vague and non-binding. What is needed are, among other things, an emergency budget, clear protocols for the Independent Complaint Mechanism (ICM), and the authority for the ICM to open cases on its own initiative. -
Adequate capacity and resources:
It remains unclear how much staff, expertise, and budget will be allocated. The resources available for outreach to communities and FI projects appear particularly limited, which raises concern. -
Complaints should be possible even after project completion:
The fact that complaints cannot be submitted once FMO has exited a project undermines the credibility of the mechanism. The impacts of investments do not simply disappear when the bank withdraws. -
Broader monitoring of compliance:
Monitoring is currently limited to management commitments. As a result, the process risks remaining inward-looking rather than truly focused on learning from mistakes and addressing harm.
An Opportunity for FMO to Make a Difference
According to the organizations involved, FMO now has the opportunity to distinguish itself as an institution that truly takes human rights seriously. This, however, requires more than technical improvements. It calls for political will, genuine transparency, and the courage to make sensitive issues public.
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This submission was prepared by organisations that have documented FMO’s harmful investments over the past decade and have engaged with the Independent Complaints Mechanism (ICM).
This submission was prepared by international organisations specialising in independent accountability and complaints mechanisms.
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Letter / 10 June 2022
Joint submission on FMO’s Position Statement on Financial Intermediaries
Both ENDS, SOMO, Oxfam Novib and Recourse sent in a submission to FMO's public consultation on its Position Statement on Financial Intermediaries. In this position statement, FMO only takes limited responsibility for the consequences of its investments through so-called financial intermediaries. We call upon FMO to publish a position statement that focuses on protecting human rights and the environment and take full responsibility for this.
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Letter / 9 November 2020
Input into FMO’s public consultation on Climate Action Commitments and Fossil Fuel Statement
Both ENDS and partners gave their input on FMO's public consultation on Climate Action Commitments and Fossil Fuel Statement. Both ENDS and partners are pleased that FMO is finally taking a stand regarding fossil fuels, but in our opinion it could be more ambitious.
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Letter / 3 March 2025
Input for FMO’s “investment approach to responsibly managed forest plantations”
Both ENDS has been asked by FMO to comment on its draft investment approach to responsibly managed forest plantations. To follow are a number of observations and recommendations, partially informed by Both ENDS long legacy of working in the forest & land arena, in dialogue with international donors, philanthropic foundations, companies, certification bodies and notably with forest dependent communities and other land users.
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News / 27 July 2021In conversation with the Ngäbe-Bugle community in Panama, after five years of Barro Blanco-dam
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News / 8 November 2021Both ENDS and SOMO condemn violence against Indigenous community near the Barro Blanco dam in Panama
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Dossier /Large-scale infrastructure
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Publication / 25 May 2023
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News / 10 July 2020Honduran NGOs call on FMO not to invest in controversial bank
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Dossier /Advocating for responsible policies of development banks
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