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A Guide to the Proparco Independent Complaints Mechanism (ICM)
If Proparco funded or supported the project that is causing you harm, you may be able to file a complaint with its accountability mechanism, the Independent Complaints Mechanism (ICM).
What is Proparco?
Proparco is the private sector arm of the Agence Française de Développement/French Development Agency Group (AFD Group). Proparco finances private companies and financial institutions in developing countries through loans, equity investments, and guarantees. Proparco invests across sectors such as infrastructure, renewable energy, health, education, and financial services.
What is the ICM?
Proparco, together with the FMO Dutch Entrepreneurial Bank (FMO) and Deutsche Investitions- und Entwicklungsgesellschaft (DEG), which also have pages in this Guide, share an Independent Complaints Mechanism (ICM). The ICM consists of the Independent Expert Panel (IEP) and the respective Complaints Office of Proparco, DEG, and FMO. Proparco’s Complaints Office function is performed by Proparco’s Risk Department.
The ICM receives complaints related to harm caused or threatened by projects financed by any of these three banks. If you are, or may be, affected by a Proparco-funded project, you can file a complaint with the ICM.
If your complaint is found to be eligible, the ICM has two functions to try to resolve the complaint: dispute resolution (also known as problem solving) and compliance review. You can decide which process you would like your complaint to enter if found eligible. If you want to try both dispute resolution and compliance review, the ICM offers the flexibility to conduct either process one-after-the-other. The two functions cannot be done simultaneously. You can learn more about the difference between dispute resolution and compliance review, and which option is better for your complaint on the homepage of this guide.
Note, that the ICM Policy for the three banks are currently under revision, with an updated policy expected to be published in 2026. We are closely following this process and will update this guide as soon as possible after the publication of the new policy. You can find more information about the review process here: https://icm-consultation.org/review_and_update/.
Dispute Resolution
The ICM’s voluntary dispute resolution process (also referred to as problem solving) aims to resolve issues collaboratively. During the dispute resolution phase, the ICM will appoint a neutral facilitator who will facilitate information sharing, fact-finding, dialogue, and/or mediation, between the affected communities and Proparco’s client, with the goal of reaching mutually agreeable solutions to the issues raised in the complaint.
Dispute resolution is a voluntary, flexible process and depends on the willingness of all parties to participate. If an agreement is reached, the facilitator will help the parties to formalize it. If the process fails, the complaint may proceed to compliance review (if it hasn’t already been undertaken).
You can learn more about this phase below.
Compliance Review
At the ICM, the fact-finding investigation process is called “compliance review”. During the compliance review, the ICM investigates whether Proparco has complied with its policies, and whether any non-compliance has contributed to harm to the community. The ICM then prepares a compliance report with findings and recommendations. Recommendations may include steps needed to correct the issues with the project, or avoid similar issues in the future.
Proparco’s Management is required to respond to the report and develop an action plan to address the findings. The Complaint Office (the Risk Department) monitors the implementation of these actions.
You can learn more about this phase below.
Can you complain to the ICM?
Before filing a complaint, ask yourself the following questions. If your answer is YES to all of the questions, then you can complain to the ICM.
The ICM accepts complaints about projects that are actively being funded, or “will” be funded, by Proparco.
Tip: You can find information about projects in the AFD Group Project Database, via an information request, by emailing transparence@afd.fr, or through the DeBIT tool (a database you can search).
The ICM accepts complaints from:
- One or more people, groups, or organizations who are experiencing (or are likely to experience) harm as a result of an Proparco-supported project.
- Authorized representatives can file a complaint on behalf of affected individuals or communities.
Important: Complaints cannot be submitted anonymously, but you can request confidentiality regarding your identity or sensitive information. If you fear retaliation, notify the ICM immediately to discuss protective measures.
The complaint could be about human rights abuses, or other environmental and social impacts or risks, which negatively affect you and which are linked to the project financed by Proparco. If possible, you should explain how Proparco has contributed to this harm (for example, by failing to comply with its policies).
The ICM may require that complainants attempt to resolve concerns with Proparco, its client, or other authorities before submitting a complaint to the ICM. If you are not able to meet this requirement, for example due to fears of retaliation, bad experiences with project stakeholders, or severe communication barriers, you should explain this in your complaint. At the time of publication of this guide, we are not aware of any complaints being rejected for not meeting this requirement.
Online complaint form
Complaint filing checklist
Download checklistStrengthen your complaint by referencing Proparco policies
When filing your complaint to the ICM, you may want to reference Proparco policies that were violated. Environmental and social safeguard policies, in particular, play an important role in your complaint. These safeguards are rules and policies designed to identify and mitigate risks associated with Proparco activities, with an overarching goal of preventing environmental and social harms. Understanding these safeguards is essential for anyone seeking to hold banks accountable for harms associated with their investments.
The Proparco ICM Policy states that the ICM reviews Proparco’s compliance with its policies, including concerns that Proparco has failed to comply with the “E&S Principles” and Exclusion List of the AFD Group. It is not entirely clear what “E&S Principles” refers to here and we are seeking clarification. The AFD does have an Environmental and Social Risk Management Policy, which incorporates the World Bank Group’s Standards, including the World Bank Environmental and Social Framework and its Environmental, Health and Safety Guidelines (EHSG).
Proparco also conforms to the European Development Finance Institutions’ “Principles for Responsible Financing of Sustainable Development” and its Harmonised ESG Standards, which require compliance with the IFC Performance Standards in addition to the EHSG. We’ve tried to highlight the most relevant policies and obligations below, and will update this Guide as we learn more.
NOTICE: Including references to these policies is optional but can strengthen your complaint by identifying clear grounds for Proparco’s accountability.
AFD Group Policies
The E&S Policy applies to all projects financed directly or indirectly (through another bank) by the AFD. The E&S Policy places the following obligations on AFD and its clients:
- Risk Assessment: Every project must undergo environmental and social due diligence before approval to identify potential harms and design measures to avoid, minimize, or offset them.
- Stakeholder Engagement: For high and substantial risk projects, the environmental and social risk assessments and action plans must be subject to a free, prior and informed consultation of the people potentially affected by the project, as well as civil society representatives involved in environmental and social issues. Consultations must be transparent, accessible, and culturally appropriate.
- International Standards: In addition to its own standards, AFD applies global frameworks, including:
- World Bank Environmental and Social Standards
- World Bank Group’s Environmental, Health and Safety Guidelines (EHSG).
More information about the World Bank’s safeguards are available on the World Bank page of this Guide. Taken together, these standards require that AFD projects:
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- Integrate protections for community health and safety, the climate, biodiversity, pollution prevention, and resource efficiency into its project assessments and financing decisions,
- Pay special attention to Indigenous peoples, women, and marginalized communities, ensuring their rights, cultures, and livelihoods are respected,
- Avoid involuntary resettlement where possible. If unavoidable, AFD projects must provide fair compensation, livelihood restoration, and respect for international best practice, and
- Respect International Labour Organization (ILO) standards, including prohibition of child and forced labor, safe working conditions, and freedom of association.
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- Other Human Rights, Development, and Climate Commitments: The AFD also commits that the projects the AFD it finances ‘contribute to France’s ODA strategy, the implementation of the 2030 global agenda and the 17 Sustainable Development Goals, as well as the 2015 Paris Climate Agreement.’
- Monitoring and Supervision: AFD must monitor projects during implementation to ensure that environmental and social commitments are being followed. This includes checking compliance with safeguards, reviewing corrective measures, and adjusting requirements if risks change.
- Transparency and Accountability: AFD commits to publishing project information and ensuring affected communities have ways to raise concerns and seek redress.
- The AFD Group, including Proparco, is not permitted to finance certain activities, including -
- Any activity that is illegal under the laws of the host country or or of France;
- Any project involving forced labour or child labour;
- An irreversible harm to nationally- or internationally-recognized cultural heritage;
- Fossil-fuel projects, including projects related to: fossil-fuel power plants; infrastructure associated with producing, storing or processing fossil energy resources (mines, processing facilities, storage, etc.) or for generating electricity from fossil energy sources; and the exploration, production, processing, or exclusive transportation of coal, gas and oil;
- Projects within world heritage sites or legally protected areas;
- Large scale forest or agriculture projects that result in deforestation;
- Projects whose purpose and/or approach are inconsistent with human rights;
- Projects resulting in forced eviction that is is materially impossible to compensate;
- Among others.
The Association of European Development Finance Institutions policies
As a member of the Association of EDFIs, Proparco has committed to:
- Follow the law: Make sure their clients, including banks and other financial institutions, comply with local legal and regulatory requirements wherever they operate.
- Prevent harm: Require clients to reduce risks of negative impacts on people, communities, and the environment. This includes following international standards such as the IFC Performance Standards, the World Bank’s Environmental, Health and Safety Guidelines, International Labour Organization rules, and internationally-recognized human rights standards. Clients are also encouraged to extend these standards to their supply chains, including contractors.
- Consultation: Encourage clients to have open discussions with local people and other stakeholders about the environmental and social impacts of their activities.
- Maximize positive impacts: Commit to ongoing improvements in how environmental, social, and human rights issues are managed, to maximize positive impacts for people, workers, and communities.
- Act on climate: Support the Paris Climate Agreement by directing finance toward low-emissions, climate-resilient development.
- Be transparent: Provide clear and accountable information about investment activities, while respecting commercial confidentiality and client privacy.
World Bank Group Policies
The World Bank requires its clients to comply with ten performance standards, relating to: Assessment and Management of Environmental and Social Risks and Impacts; Labor and Working Conditions; Resource Efficiency and Pollution Prevention and Management; Community Health and Safety; Land Acquisition, Restrictions on Land Use and Involuntary Resettlement; Biodiversity Conservation and Sustainable Management of Living Natural Resources; Indigenous Peoples/ Sub-Saharan African Historically Underserved Traditional Local Communities; Cultural Heritage; Financial Intermediaries; and Stakeholder Engagement and Information Disclosure. You can find more information on the World Bank page of this Guide.
The EHSG require projects to follow international good practice to prevent harm to people and the environment. This means controlling pollution (air emissions, wastewater, noise, waste, and hazardous materials), protecting workers through safe conditions and training, safeguarding nearby communities from health and safety risks, and managing impacts during construction and closure. Projects must also monitor and report their performance, engage with affected stakeholders, and restore sites responsibly. You can find more information on the World Bank page of this Guide.
The IFC requires its projects to meet the a series of eight performance standards relating to: Assessment and Management of Environmental and Social Risks and Impacts; Labor and Working Conditions; Resource Efficiency and Pollution Prevention; Community Health and Safety; Land Acquisition and Involuntary Resettlement; Biodiversity Conservation and Sustainable Management of Living Natural Resources; Indigenous Peoples; and Cultural Heritage. You can find more information on the IFC/MIGA page of this Guide.
Within five working days of receiving your complaint, the ICM will acknowledge receipt of the complaint and forward it to the Independent Expert Panel (IEP). The IEP is a key component of the ICM: it is made up of three panel members who are independent of (and do not work for) Proparco, with expertise in areas like human rights, the environment, or development. If the complaint is filed in a language other than English, additional time may be needed for translation.
Within a further 25 working days, the IEP will determine whether the complaint is "admissible" for the ICM process. Although the ICM refers to this stage as admissibility, it is similar to the "eligibility" phase at other complaint offices. The IEP will assess:
- Project: The complaint must be related to a project actively funded (or “will” be funded) by Proparco.
- Harm: The complaint must raise concerns about substantial harm (particularly environmental and/or social risks and impacts) that was or may be caused by the Proparco project.
- Impact on the complainant(s): The complainant(s) is/are currently or likely to be affected by the harm described in the complaint.
- A connection between the harm and Proparco's actions or omissions: There must be some connection between the harm and Proparco failing to comply with its policies.
- Prior efforts: The ICM may require that complainants attempt to resolve concerns with Proparco, its client, or other authorities before submitting a complaint to the ICM, however we are not aware of any complaint being rejected for not doing this. The IEP may make exceptions if you fear retaliation or face other barriers to meeting this requirement.
Your complaint will not be found admissible/eligible if it is:
- Filed mainly to get a business advantage, or if it is repetitive of prior complainants, frivolous, or malicious; or
- The same as another complaint that is already being dealt with by another complaint office or a court. If an identical complaint is already being reviewed somewhere else, the IEP can still undertake a compliance review for your complaint, but it may pause its work until the other review is finished. If the project you are complaining about is financed by multiple banks with complaint offices, it is possible to file a complaint with more than one of those banks, and the ICM will seek to cooperate/collaborate with them to avoid duplication or disruption.
The IEP makes the final decision on admissibility/eligibility. If your complaint is deemed admissible/eligible (or partially so), IEP will proceed to the “Preliminary Review” stage and the ICM will publish a summary of the complaint on its website (unless confidentiality prevents this).
If your complaint is found inadmissible/ineligible, the ICM will close the complaint file and inform you in writing about this decision. The ICM does not publish ineligible complaints on its website.
Once a complaint has been found eligible, the IEP will launch a “Preliminary Review” into the issue(s) raised by the complainant(s). The purpose of this preliminary review is to better understand the community’s concerns and the position of Proparco and its client, and to identify any information relevant to how the complaint should be managed. This includes asking the parties whether they are interested in participating in a dispute resolution process.
The IEP will review important documents and meet with relevant people — including the complainants, the company, Proparco staff, government officials, and civil society groups — to collect the information it needs.
The Panel will aim to finish the preliminary review within a reasonable timeframe, however the number of days to finish the preliminary review will depend on the complexity of the case and will be communicated to all parties involved.
This stage will end with a preliminary review report, which will summarize the information gathered and note whether parties have agreed to a dispute resolution or whether the complaint will be entering compliance review.
All complaints that have been assessed and not closed should then enter a substantive phase. As mentioned, the ICM offers the flexibility of conducting compliance review and dispute resolution, in any order.
Dispute Resolution
Dispute resolution is a voluntary process where the ICM helps facilitate a “problem-solving” process between you (the complainant), the client (the organization implementing the project), and other stakeholders as appropriate.
This process can involve dialogue and negotiation, mediation, information sharing, or joint fact-finding. The ICM may act as the facilitator, or appoint an external mediator, as long as all parties agree on the selected mediator.
This process can and should be designed and implemented together. The aim of a dispute resolution is to reach an agreement between all the parties, and find a mutually agreeable solution to your concerns.
The dispute resolution process can continue as long as needed and all participants in the mediation process are committed to moving the process forward.
Voluntary: Since dispute resolution is voluntary, any party can choose not to participate and participation requires consent from all involved. If parties agree to participate, communities can share their concerns about the project directly with Proparco’s client and advocate for specific solutions to their concerns.
Outcome: If the parties reach an agreement, the IEP will help them to formalize those solutions in a signed agreement and will monitor its implementation. If no agreement is reached, or if an agreement is not implemented, the case will be transferred to compliance review. Upon completion of this phase, the IEP will prepare a report on the results of the dispute resolution, which will be published on the ICM’s website.
For more details on the dispute resolution process, refer to the Proparco ICM Policy.
Compliance Review
If your complaint is found eligible for compliance review, the IEP will conduct an investigation (known as a compliance review) to determine whether Proparco failed to follow its environmental and social rules when financing the project.
To do this, the IEP may:
- Speak with affected people, the company, government officials, Proparco staff, and civil society groups,
- Visit the project site,
- Ask for written or oral submissions, and
- Bring in independent experts to look at specific issues.
The IEP then prepares a draft report with findings on whether Proparco complied with its policies. If the draft report finds that Proparco has failed to comply with its policies, it will also include recommendations for how Proparco can bring the project into compliance, and how to avoid similar issues in the future.
The IEP will share a copy of this draft report with the Proparco first, and subsequently complainants and Proparco’s client, for feedback.
After considering their comments, the IEP issues a final Compliance Review Report. The final report is sent to the Management Board and Supervisory Board of Proparco.
The Proparco Management Board will provide a Management Response to the final report within five days. This response should include an action plan for corrective actions, with detailed timeframes for implementation.
The ICM will then send the final Compliance Review Report, with the Management Board’s response, to the complainant(s), and publish them on Proparco’s website.
For more details on the compliance review process, refer to the Proparco ICM Policy.
If your complaint goes through a dispute resolution process and results in an agreement, or goes through a compliance review and a Management Action Plan is published, then the complaint will enter a monitoring phase. The ICM publishes monitoring updates, and the complaint is closed when commitments have been met.
Dispute Resolution
According to the IEP, any agreement reached between the parties should include specific timelines and procedures for monitoring agreed actions. The IEP will commit to monitor the implementation of that agreement.
The IEP will close the case and cease monitoring when it is satisfied that the agreed actions have been implemented to the satisfaction of the parties.
Compliance Review
If Proparco was found to be non-compliant with its environmental and social policies, Proparco’s Management Board is responsible for developing an action plan to address the issues identified in the IEP report. The action plan should include detailed timeframes for implementation.
The Proparco Complaints Office is responsible for monitoring the implementation of this action plan. A monitoring exercise should be conducted within one year of the Compliance Review Report being finalized.
Comparison to best practice
Independence: The IEP is largely independent from bank management; it principally reports to Proparco’s Supervisory Board.
Independence: The Proparco Complaint Office, in contrast, is not independent of bank management, and plays a significant role in monitoring the outcomes of complaints.
Transparency: Although the ICM provides some transparency, there are some important gaps. The ICM does not publish details of ineligible complaints, other than select data in its Annual Reports. For eligible complaints, only a summary of the complaint is published, alongside eligibility reports, final compliance reports, and dispute resolution reports.
Remedy: While the ICM can make recommendations for actions that should be taken to address areas of non-compliance, it does not explicitly have a mandate to recommend remedial measures to address harm to communities.
A look at the data
We have brought together some charts, based on the latest data available in the Complaint Dashboard, to offer a deep dive into Proparco's and the ICM's performance.
Complaint Outcomes
Eligibility
Dispute Resolution Outcomes (when undertaken)
Compliance Review Findings (when undertaken)
Complaint issues
Complaint sectors
Policy recommendations to strengthen the ICM
The ICM should report directly (and solely) to Proparco’s Supervisory Board, manage its own budget as approved by the Supervisory Board,, and have a full-time Chair and dedicated mechanism staff, independent of bank management. (GPP 5, 6, and 8)
The ICM should allow complaints for a period of at least two years after the end of Proparco’s financial relationship with the project or two years after the complainant first became aware of the harm, whichever is later. (GPP 31)
The ICM’s policy should include an express mandate to monitor the remediation of all instances of non-compliances found. (GPP 57)
The ICM should be required to publish and share with the Supervisory Board all monitoring reports and inform them of any instances of failure to address harm. (GPP 59)
The ICM should have the authority to recommend the suspension of a project in the event of imminent harm. (GPP 43)
The ICM policy should require a regularly updated case registry which include pending, ineligible, completed and closed cases, with links to all relevant documentations (e.g. complaint form, eligibility decisions, dispute resolution reports and agreements, compliance review reports, monitoring reports) available permanently in full, not merely in summarised form. (GPP 21)
To send complaints:
complaints@independentcomplaintsmechanism.orgOnline complaint form:
https://www.proparco.fr/en/form/submit-environmental-and-social-complaintComplaints Office
Proparco
151 rue Saint-Honoré
75001 Paris
France
Date Last Updated: Feb. 8, 2026