Green Climate Fund (GCF) | Independent Redress Mechanism (IRM)
The Green Climate Fund was established in 2010 by 194 countries party to the United Nations Framework Convention on Climate Change (UNFCCC). The GCF aims to support a paradigm shift in climate-change response by investing in low-emission and climate-resilient projects and programs in developing countries. It focuses in particular on the needs of societies facing severe impacts due to climate change, including Least Developed Countries (LDCs), Small Island Developing States (SIDS), and African States. The GCF provides investment to “accredited entities” such as public institutions, development or commercial banks, or private companies that implement climate-resilient projects.
Green Climate Fund (GCF)
Created In: 2010
Headquarters: Songdo, South Korea
Member Countries: 194
Mission: The Green Climate Fund (GCF) is a new global fund created to support the efforts of developing countries to respond to the challenge of climate change. GCF helps developing countries limit or reduce their greenhouse gas (GHG) emissions and adapt to climate change. It seeks to promote a paradigm shift to low-emission and climate-resilient development, taking into account the needs of nations that are particularly vulnerable to climate change impacts.
The Accountability Office: Independent Redress Mechanism (IRM)
Established in: 2017
Functions: Problem Solving, Compliance Review
GCF investments must comply with its Environmental and Social Policy to ensure that its investments are in keeping with its mission. GCF investments are also subject to its Indigenous Peoples Policy and Gender Policy and Action Plan.
The GCF uses a monitoring and accountability framework that requires accredited entities to submit annual self-reports on their compliance with the safeguards. In the GCF’s Information Disclosure Policy, the Fund commits to disclose any information not contained in a list of exceptions on its website, through other appropriate means, or upon request. The exceptions to disclosure include personal information, confidential information, and certain financial information that, if disclosed, may prejudice the financial or commercial interests of the GCF and its activities.
The Accountability Office
The Independent Redress Mechanism (IRM) was established to address reconsideration of funding decisions and “address the grievances and complaints by communities and people who have been directly affected by the adverse impacts through the failure of the project … to implement the Fund’s operational policies and procedures, including environmental and social safeguards.” The IRM’s terms of reference can be found here.
The IRM operates according to its Procedures and Guidelines. The IRM receives complaints from individuals or group of persons who have been or may be adversely affected by a GCF-funded project or program. The IRM has two functions available to complainants:
- Problem Solving – a participatory process focused on assisting the parties find effective solutions to the concerns raised by the complainant.
- Compliance Review – an investigative process in which the IRM will examine whether the GCF-funded project or program at issue failed to comply with applicable policies and procedures and whether such non-compliance caused or may cause harm.
For more information, visit the IRM’s website.
Accountability Counsel works with our partners to amplify the voices of those impacted by GCF funded projects to achieve greater accountability for climate change and climate adaptation investments. In a world that desperately needs climate finance to be effective in reducing carbon emissions, our work seeks to ensure that communities can raise grievances about projects that allow misappropriation of funds, or will cause negative social and environmental impacts.
Over the past four years, Accountability Counsel’s advocacy began with the inception of the GCF accountability process and continues today to ensure that the GCF accountability office meets best practice.
On November 1, 2016, Lalanath de Silva assumed office as the head of the Independent Redress Mechanism (IRM). Accountability Counsel and 25 partner organizations sent de Silva a welcome letter calling on him and the GCF to design and implement an accessible, responsive, and effective IRM. Mr. de Silva responded in a letter recognizing the challenges that communities face in accessing remedies for the negative impacts of development activities and expressing his commitment to working with the civil society organizations as head of the IRM. Mr. de Silva also announced that in 2017 the IRM would focus on preparing a revised Terms of Reference (TOR), which established the IRM within the GCF, followed by detailed guidelines and procedures, which would govern the operation of the IRM.
Shortly after this announcement, the GCF released a public call for submissions on revising the IRM’s TOR. The call for submissions suggested a number of questions for public submissions to address, including how the TOR could be revised:
- To adequately cover all complaints received by the IRM under the GCF’s Governing Instrument;
- To take into account how the IRM should relate to or collaborate with similar redress mechanisms of accredited entities and implementing entities;
- To ensure redress is delivered in a timely and efficient fashion; and
- To ensure the lessons learned by the IRM are incorporated into the day-to-day work of the GCF.
Accountability Counsel collaborated with civil society partners in submitting recommended revisions to the TOR for the IRM on January 20, 2017. One submission included input from a range of global organizations. We also worked closely with our partners at the Center for International Environmental Law (CIEL) and the Centre for Research on Multinational Corporations (SOMO) on another submission. Both submissions stressed the importance of ensuring that the IRM is responsive, accessible, transparent, predictable, and independent. Namely, the submissions advocated for allowing all project-affected people to file complaints with the IRM, even if they can or do file with other grievance mechanisms at accredited entities and implementing entities, because the IRM is best suited to analyze whether GCF policies were met. We also called on the GCF to commit to establishing a compensation and remedy fund that can be used to help complainants cover the costs of seeking redress through the IRM. All of the submissions received on the TOR can be found here.
On September 25, 2017, the GCF’s Board approved the final TOR as a decision between Board meetings. The GCF also committed to launching a separate consultative process for developing guidelines and procedures for the IRM. Accountability Counsel partnered with civil society groups to provide a letter and joint comments on the Draft Procedures and Guidelines for the IRM. We also participated in a May 2018 consultation with IRM Head Lalanath de Silva to advise on ways to strengthen the mechanism’s proposed procedures. Our policy team emphasized the need to create an easily accessible venue, which included recommendations to ensure that human rights defenders and other complainants have safe avenues for their voices to be heard, and to extend the window for filing claims past the one-year deadline proposed in the Draft Guidelines.
On 28 February 2019, the Board approved the final Procedures and Guidelines of the IRM. Reflecting years of advocacy by Accountability Counsel and its partners, the Procedures and Guidelines include a number of strong and innovative provisions that can serve as good practice for the wider accountability ecosystem.
In April 2020, Accountability Counsel joined partner organizations to submit comments on the IRM’s Draft Standard Operating Procedures on Retaliation. Our comments urged the IRM to clarify, among other things, how it will interact with the GCF’s Independent Integrity Unit to address claims of retaliation, and how it will address persistent and new instances of reprisals if the GCF has enabled but is no longer involved with a project of concern.
Documents By Release Date
Feb 2019 – GCF’s Board of Directors approved the final Procedures and Guidelines of the IRM which includes a number of strong and innovative provisions, reflecting years of advocacy by Accountability Counsel and its partners.
Jun 2018 – Accountability Counsel, and other global partner organizations, submitted joint comments on the GCF’s draft Procedures and Guidelines of the IRM.
Apr 2018 – GCF called for public comments on its draft Procedures and Guidelines of the IRM.
Sep 2017 – GCF’s Board of Directors approved the revised Terms of Reference (TOR) for GCF’s Independent Redress Mechanism.
Mar 2017 – Accountability Counsel, and other global partner organizations, submitted joint comments on the revised Terms of Reference (TOR) for GCF’s Independent Redress Mechanism.
Jan 2017 – Accountability Counsel, CIEL, and SOMO submitted joint comments on the revised Terms of Reference (TOR) for GCF’s Independent Redress Mechanism.
Dec 2016 – Lalanath de Silva’s response letter to Accountability Counsel’s welcome letter
Nov 2016 – Accountability Counsel, and several partner organizations, sent a welcome letter to the new head of the IRM, Lalanath de Silva.