Accountability at the IFC & MIGA

How to File a Complaint

Any individual, community or other party affected or likely to be affected by the environmental and social impacts of an IFC or MIGA project may lodge a complaint with the CAO. Complaints may also be raised on behalf of affected persons, provided that complainants prove their authority to represent them. Complaints must be written, but may be submitted in any language. Issues may be raised concerning the procedures followed during preparation or implementation of a project, mitigation of social and environmental impacts, and/or involvement of interested persons and affected communities in the project cycle. In addition to providing the complainant’s contact information, a complaint must include the name or description of the project of interest and information about the project’s effects or likely impacts on the complainant. The complaint should include a description of how the affected party or parties would like to see problems resolved through the CAO grievance process.

• CAO’s Web page on “How to Submit a Complaint”

Tracking the CAO Process

The following table reflects CAO protocol in handling complaints:

At the time a complaint is accepted, the relevant IFC or MIGA management, project sponsors, and other interested parties are notified of the complaint, but the CAO will respect the confidentiality of complainants’ identities when requested to do so. Depending on how the CAO has chosen to proceed with the complaint, it may continue to address it through the Ombudsman function or may treat the case under its compliance or advisory capacity to conduct an audit or offer advice to IFC or MIGA. If the CAO decides to proceed in its Ombudsman capacity, it may carry out an investigation of the complaint, facilitate mediation or conciliation efforts between the parties, or recommend immediate actions. Complaints will be closed when a satisfactory agreement or settlement is reached or when the CAO determines that further investigation or mediation will not be productive. The CAO is responsible for following up on agreements reached to ensure their continued effectiveness and acceptability to parties involved.

• More on the CAO's mediation role (CAO website)

CAO complaint processes in which BIC has been involved

• Bujagali Hydroelectric Project, Uganda
• Niger Delta Contractor Revolving Credit Facility, Nigeria

• Bulyanhulu Gold Mine, Tanzania

Analysis of the CAO

There is no consensus from civil society groups who have engaged the CAO on whether or not the office’s services have been helpful in resolving problems associated with IFC and MIGA projects. Divergent experiences with the CAO have led some groups to dismiss the office’s potential to influence significant changes in IFC or MIGA operations and even to conclude that the CAO poses a threat to the reputation of complainants and their ability to redress grievances, while others remain hopeful that the CAO provides a mechanism through which to enforce the accountability of the IFC and MIGA for the impacts their projects have on individuals and communities.

In its advisory function, the CAO has produced reviews of the social and environmental policies of IFC and MIGA, as well as evaluations of their extractive industries activities as input into the World Bank Group Extractive Industries Review.

The CAO has completed one compliance audit to date in 2001. See the report on the CAO website:

• Preliminary Audit Review of MIGA in Relation to Compania Minera Antamina S.A, February 2001 (CAO website)