Germany & Netherlands: German Investment Corporation (DEG) & Netherlands Development Finance Company (FMO) | Independent Complaints Mechanism (ICM)

  • Overview

    The German Investment Corporation (DEG) is the German development bank, whose mission is to finance direct investments and long-term investment capital within developing and emerging markets, contributing to sustainable economic development and expansion of the private sector.

    The Netherlands Development Finance Company (FMO) is the Dutch development bank, which serves to support sustainable private sector growth in developing and emerging markets by investing in businesses, projects, and financial institutions. Headquartered in The Hague, Netherlands, FMO investments extend to various countries around the globe and span several sectors, including energy, financial institutions, agribusiness, infrastructure, and manufacturing.

    Deutsche Investitions und Entwicklungsgesellschaft (DEG)

    Created In: 1962

    Headquarters: Cologne, Germany

    Mission: To promote business initiative in developing and emerging market countries as a contribution to sustainable growth and improved living conditions of the local population.


    The Dutch Development Bank (FMO)

    Created In: 1970

    Headquarters: The Hague, The Netherlands

    Mission: To contribute to healthy, long-term, responsible development in the business sector in developing countries, in the interest of the economical and social advancements.

    The Accountability Office: Independent Complaints Mechanism (ICM)

    Established in: 2014

    Functions: Dispute Resolution and Compliance Review

    Visit the DEG and FMO ICM Websites

    DEG’s environmental and social standards and practices include the application of the IFC Performance Standards.

    FMO investments are subject to multiple guidelines and policies, including the IFC Performance Standards. FMO additionally employs the FMO Sustainability Policy Universe, which forms the framework for FMO’s approach to environmental, social, and governance issues.

    The Accountability Office

    Together, FMO and DEG operate the Independent Complaints Mechanism (ICM). It is designed to enable affected parties to file a complaint regarding FMO or DEG-financed projects.

    The ICM has two functions:

    • Dispute resolution – this function is aimed at addressing issues raised in a complaint through a voluntary process. Dispute resolution may include information sharing, facilitated discussions, or mediation in order to reach appropriate solutions.
    • Compliance review – this function investigates whether FMO or DEG complied with their respective policies relevant to the project.

    Submit a complaint to the ICM if:

    • You are an individual, group, community, or representative
    • You have been or potentially will be negatively affected by a project financed by the FMO or DEG.

    Complaints may be submitted in any language. More information may be found at the DEG and FMO ICM websites.


    Proparco, the French development finance institution, will join the ICM in January 2019.

  • Our Advocacy

    Accountability Counsel is working with partners to ensure that the Independent Complaints Mechanism (ICM) is accessible and effective.


    ICM Policy Review

    In January 2016, the ICM announced a review of its policy and released a draft revised policy for public comment. Accountability Counsel contributed to a joint submission of recommendations to strengthen the functioning of the mechanism. Our submission included recommendations to remove barriers to accessibility to the mechanism, including restrictions on a person’s ability to submit a complaint in their own language.

    The ICM published the revised policy (DEG and FMO) in January 2017, and it incorporates several of our recommendations. Our impact includes:


    • Communities and individuals may now submit their complaints in any language.
    • The ICM no longer automatically bars requests for dispute resolution that are already being handled by another accountability or judicial mechanism. This change recognizes that a case-by-case approach should be utilized to determine whether a dispute resolution process would be possible under these circumstances.


    • The revised policy includes more concrete deadlines for the complaint process, increasing complainants trust in the process.
    • Under the revised policy, the ICM will now monitor the project until it is satisfied that DEG’s or FMO’s actions are addressing the project’s non-compliance with DEG’s or FMO’s policies.


    There are still areas where the policy and the practice of the ICM needs improvement, including:

    • The policy still allows the ICM to enter into confidential side agreements with DEG or FMO clients prior to obtaining their participation in the complaint process regarding projects that were approved prior to the ICM’s creation. This practice weakens the transparency, legitimacy, and predictability of the ICM.
    • The revised policy fails to include a formal advisory function for the ICM, which limits the ICM’s ability to provide pragmatic, evidence-based recommendations gleaned from the ICM’s dispute resolution and compliance casework, shedding light on gaps in DEG’s and FMO’s policies and their implementation.


    Accountability Counsel will continue to work with our partners to ensure that the ICM is an accessible and effectively addresses complaints related to DEG and FMO financing.

  • Documents

    Institutional Documents

    2017 Revised ICM policy (DEG and FMO)

    2014 ICM Policy


    Documents by Release Date

    Dec 2016 – DEG and FMO complaints offices’ response to the joint submission, including information on changes implemented in the revised policy.

    Feb 2016 – Accountability Counsel, and 9 civil society organizations, submitted joint recommendations for improving the draft revised ICM policy.

    Jan 2016 Draft revised ICM policy was released for consultation.