European Bank for Reconstruction and Development (EBRD) | Independent Project Accountability Mechanism (IPAM)
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Overview
Accountability Counsel advocates for the EBRD’s Independent Project Accountability Mechanism to be as effective as possible, meaning that it must be independent, legitimate, fair, transparent, predictable, and accessible.
European Bank for Reconstruction and Development (EBRD)
Created In: 1991
Headquarters: London, United Kingdom
Member Countries: 66
Largest Shareholder: United States
Mission: To develop open and sustainable market economies in countries committed to, and applying, democratic principles.
The Accountability Office: Independent Project Accountability Mechanism (IPAM)
Established in: 2020
Functions: Compliance, Problem Solving
The European Bank for Reconstruction and Development (EBRD) finances development projects and is the single largest investor in Central Europe and Central Asia. The EBRD invests mainly in the private sector, but often with public partnerships. Please see the EBRD’s homepage for more information and for specifics on EBRD projects.
Accountability Counsel has advocated for reforms to the EBRD’s accountability mechanism for years, going back to before a review was even officially underway. Through multiple submissions authored with civil society partners and extensive in-person advocacy, we illuminated for a variety of EBRD stakeholders the need for significant reforms. These reforms were necessary for addressing issues first revealed through our Communities casework.
Accountability Counsel’s commitment to these reforms paid off when, in 2019, a new policy was approved that replaced the EBRD’s previous accountability mechanism, the Project Complaint Mechanism with the new Independent Project Accountability Mechanism (IPAM). The IPAM policy, which officially went into effect in July 2020, is not only major improvement over the previous policy but also advances best practice among independent accountability mechanisms. In addition to major restructuring that brings the IPAM in line with good practice among peer mechanisms, the policy also includes a number of pioneering provisions, such as those ensuring a meaningful process for drafting and implementing management action plans.
The end result is a complaint-handling process that is more predictable for communities and more likely to result in meaningful remedy.
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Our Advocacy
Accountability Counsel was extensively engaged in the 2018-2019 review of the EBRD’s accountability mechanism policy. The end result of that review was a notably improved policy for the EBRD’s new mechanism, the Independent Project Accountability Policy (IPAM).
Our experience supporting local communities at the EBRD’s predecessor mechanism, the Project Complaint Mechanism (PCM), revealed a number of serious gaps. For example, the PCM’s roster model, whereby a different external expert was tasked with performing key mechanism functions like conducting compliance reviews, often led to inconsistency across complaints in the evidentiary standards applied, site visits, and other procedures.
Our Advocacy
Accountability Counsel and our partners began engaging in advocacy concerning the EBRD’s mechanism before the policy review was formally commenced.
In January 2017, we sent a joint letter with SOMO, OT Watch, and CEE Bankwatch Network to the EBRD president and board of directors highlighting the issues at the PCM. The letter followed up on a November 2016 EBRD board and civil society meeting on accountability at the PCM and called for several changes, including the creation of a senior-management-level for the mechanism director, a direct reporting line to the board, and the creation of guidelines for handling complaints in order to improve internal consistency.
In March 2017, we followed up on our earlier advocacy with a letter to the EBRD president and board highlighting issues in recent EBRD complaints, including our Mongolia case. The letter reiterated several recommendations for the PCM, including the development and adoption by the PCM of its own guidelines for handling complaints in order to improve internal consistency and ensure conformance with best practices for independent accountability mechanisms. In response, the EBRD has committed to raising consistency issues in future trainings with PCM experts and staff.
Accountability Counsel’s Policy Director attended the EBRD Annual Meeting and Business Forum in 2017 (Cyprus) and in 2018 (Jordan) to further advocate for accountability reforms. She and our partners met with bank leadership to raise these issues and work to ensure that the EBRD’s mechanism delivers real remedy to affected individuals and communities.
The EBRD officially commenced the review of its three major governance policies, including the accountability mechanism policy, in February 2018. This review, which also included the EBRD’s environmental and social safeguards and access to information policies, began with the first of two phases of public consultations. During the first phase of consultations, occurring from 12 February, 2018 to 10 April, 2018, the EBRD accepted written feedback on the current policies. Our joint submission of comments on the PCM Rules of Procedure then in effect and the functioning of the mechanism can be found here.
In January 2019, the EBRD published its draft Project Accountability Policy. The draft reflected many of our recommendations, especially those on structure and governance, though a number of issues remained. The release of the draft policy marked the beginning of the second phase of public consultations. In London in March 2019, Accountability Counsel and its partners advocated for additional improvements to the draft Project Accountability Policy at an in-person consultation and a roundtable discussion between civil society and the board. Shortly thereafter, Accountability Counsel and 24 CSOs submitted joint comments and recommendations on the draft policy.
The final version of the Project Accountability Policy was approved by the board in May 2019. The final policy built on the improvements in the draft policy, incorporating additional recommendations and further strengthening the accountability framework of the EBRD.
With IPAM operational under the new policy as of July 2020, Accountability Counsel will continue our advocacy to ensure that IPAM is fully equipped to effectively address harm stemming from EBRD investments.
See here for more information on Accountability Counsel’s advocacy to the EBRD.
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Past Advocacy
Examples of Past Advocacy Campaigns
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Resources
European Bank for Reconstruction and Development (EBRD)
Created In: 1991
Headquarters: London, United Kingdom
Member Countries: 66
Largest Shareholder: United States
Mission: To develop open and sustainable market economies in countries committed to, and applying, democratic principles.
The Accountability Office: Independent Project Accountability Mechanism (IPAM)
Established in: 2020
Functions: Compliance, Problem Solving
The Accountability Office
The EBRD’s accountability office is the Independent Project Accountability Mechanism (IPAM). IPAM provides people and civil society organizations affected by EBRD-financed projects a means to raise complaints with the bank. IPAM has two functions:
- Problem Solving – through this function, IPAM engages with complainants, clients, and other stakeholders as a neutral third party, in order to help find mutually-satisfactory agreements to resolve environmental and social issues.
- Compliance – through this function, IPAM determines whether EBRD has complied with its environmental and social and access to information policies and, if non-compliance is found, proposes remedial measures.
IPAM processes complaints submitted by:
- Individuals or organizations who believe themselves to be (or to be likely to be) affected by an EBRD project, or
- For compliance review complaints only, organizations not directly or personally affected by a project if complaint shows that efforts were made to engage with project-affected people and that project-affected people are prevented from submitting a complaint themselves.
Complaints must include information about a project supported by the EBRD and the harm that the project has allegedly caused or is likely to cause. IPAM determines eligibility and proceeds with problem solving, a compliance review, or both. IPAM issues public reports of findings, EBRD management responds, then IPAM monitors and publicly reports on the implementation of any approved actions to correct noncompliance.
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Documents
Institutional Documents
Access to Information Directive
Environmental and Social Policy
Guidance on Case Handling under the EBRD Project Accountability Policy
Key Documents by Release Date
December 2023 – Accountability Counsel shared recommendations for strengthening IPAM leading into the 2024 Project Accountability Policy review.
August 2023 – Accountability Counsel led 27 organizations in submitting recommendations to the European Bank for Reconstruction and Development on how to include remedy throughout its Environmental and Social Policy.
May 2023 – Accountability Counsel attended the EBRD’s Annual Meeting in Samarkand and urged the review of its Environmental and Social Policy to include a new approach to remediating harm to project-affected communities.
May 2022 – Accountability Counsel attended the EBRD’s Annual Meeting in Marrakech and advocated for the EBRD to establish a framework for remedying environmental and social harm caused by its investments.
May 2022 – Accountability Counsel and 18 other civil society organizations published an issue paper, titled “EBRD human rights due diligence based on safe and meaningful public participation,” and shared the paper with the EBRD at its annual meeting in Marrakech.
May 2019 – EBRD Board of Directors approved the final version of the Project Accountability Policy, which incorporated additional recommendations and further strengthens the EBRD’s accountability framework.
Mar 2019 – Accountability Counsel and partners submitted joint comments on the draft Project Accountability Policy, following an in-person consultation and roundtable discussion between civil society and the EBRD Board where Accountability Counsel and partners advocated for additional improvements to the draft policy.
Jan 2019 – EBRD published its draft Project Accountability Policy for public consultation.
Apr 2018 – Accountability Counsel and partners submitted joint comments to EBRD on its current PCM Rules of Procedure and the functioning of the mechanism.
Mar 2017 – Accountability Counsel and partners sent a follow up joint letter to EBRD President and Board of Directors highlighting issues in recent EBRD complaints, including Accountability Counsel’s Mongolia case.
Jan 2017 – Accountability Counsel, and our partners SOMO, OT Watch, and CEE Bankwatch Network, sent a joint letter to the EBRD President and Board of Directors highlighting issues at the PCM and providing recommendations.
Mar 2014 – Accountability Counsel and partners submitted Joint Civil Society Comments on the 2nd Round of EBRD’s PCM Review
Mar 2014 – Accountability Counsel contributed to the Joint Civil Society Statement on the EBRD’s Draft Environmental and Social Policy
Jan 2014 – EBRD issued Draft Project Complaint Mechanism Rules of Procedure and Draft Environmental and Social Policy for public comment
May 2013 – Accountability Counsel and partners submitted Joint Civil Society Comments on the EBRD’s PCM Review and Attached Exhibit
May 2012 – EBRD Project Complaint Mechanism 2012 Annual Report
May 2010 – EBRD’s 2010 Project Complaint Mechanism Rules of Procedure
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Related Cases
Mongolia
Accountability Counsel has supported Mongolian herders’ complaint to the Projects Complaint Mechanism, the accountability office for the European Bank for Reconstruction and Development, raising concerns about the OT project’s impacts on local water resources and the impact of a diverted river.
Read more about our case in Mongolia
Ukraine
Villagers living next to the Vinnytsia Poultry Farm in Ukraine are frightened by the possibility of risks to their health and environment. Accountability Counsel is supporting the villagers through a joint dialogue process with the poultry company, facilitated by the IFC’s Compliance Advisor Ombudsman (CAO) and the EBRD’s Project Complaint Mechanism (PCM), to answer their questions and address their concerns.