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IRM - what you can complain about

The function of the Independent Recourse Mechanism (IRM) is to assess and review complaints about EBRD-financed projects, to determine whether the Bank has acted properly in accordance with its policies and procedures, or to develop an effective process for resolving the problem raised in the complaint. The specific policies that are applicable to the IRM are:

A complaint can be made about any aspect of a Bank-financed project, from planning through to implementation. Once a complaint is registered, there is an assessment of whether the complaint is eligible for compliance review, or a problem-solving initiative, or both or neither.

The following question and answer section is written as if the group (or the authorised representative) is asking the questions and the IRM is responding.

What projects can be the subject of a complaint?
You can make a complaint about any of the Bank’s operations including loans, equity investments, guarantees and technical assistance.

What aspects of a project can be the subject of a complaint?
Anything to do with the planning or implementation of the project, or the impact of the project on the community.

On what grounds is a complaint not registered?
If the Chief Complaince Officer decides that the complaint is:

  • not complete and does not include all required information
  • clearly frivolous or malicious
  • clearly made to gain a competitive advantage through delaying the project or the disclosure of information
  • outside the scope of the IRM. This would include complaints about procurement, an allegation of fraud or corruption, the suitability of Bank policies in general or matters that only the Board of Directors can consider. We would refer any matters outside the IRM’s scope to the relevant Bank department for a response.

Can a complaint that has previously been assessed and rejected be resubmitted?
Only if you present new information that was not available when the previous eligibility assessment was completed.

What factors does the Bank consider when assessing whether a compliance review is appropriate?
Whether the Bank may have acted in any material way that does not comply with its Environmental Policy or project-specific provisions of the Public Information Policy.

What do you exclude when assessing whether a compliance review is appropriate?
We do not review actions that are the responsibility of a third party, or that relate to the laws, policies and regulations of the country in which the project is located and which do not amount to possible material violations of Bank policies.

What do you consider when assessing whether a problem-solving initiative is appropriate?
Whether the relevant parties want to participate in a problem-solving initiative, and whether it is likely to help the parties to resolve their differences.

Further information in this section:



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