The PCM process is governed by the PCM Rules of Procedure, which set out the rules about how a complaint may be filed and how it will be processed. They also set out the requirements relating to timelines, reports, disclosure of and access to information, training, outreach and other issues relevant to the administration of the PCM. The current PCM Rules of Procedure were approved by the EBRD Board of Directors in May 2014 and came into force on 7 November 2014. They guide the review process for complaints submitted after this date. Complaints registered before 7 November 2014 will continue their review process under the PCM Rules of Procedure 2009.
PCM Rules of Procedure
Guide for EBRD Clients
Functions of the PCM
PCM has two functions:
- a Compliance Review function which seeks to assess whether a Bank approved project complies with relevant the EBRD’s policies, specifically relevant environmental policies and project-specific provisions of the Public Information Policy, and
- a Problem-solving Initiative which has the objective of restoring dialogue between the parties, where possible, to trying to resolve the underlying issues giving rise to the complaint or grievance. A problem-solving initiative might include independent fact-finding, mediation, conciliation, dialogue facilitation, investigation or reporting.
Following the assessment of a complaint, there may be a recommendation for a Compliance Review and/or Problem-solving Initiative, or neither.
Who may submit a complaint?
One or more individual(s) or Organisation(s) may submit a complaint seeking a Compliance Review.
Administration of the PCM
The PCM is independent from the EBRD’s banking operations and the Environment and Sustainability department. It is administered by a dedicated PCM Officer who is located within the EBRD’s Office of the Chief Compliance Officer (OCCO) and is responsible for the overall, day-to-day operations and external relations of the PCM.
Additionally, a roster of independent experts assists the PCM Officer in the process. Their functions include the assessment, together with the PCM Officer, of the eligibility of complaints, the undertaking of Compliance Reviews or Problem-solving Initiatives and follow up monitoring.
When a complaint is received and registered, the PCM Officer will appoint an independent expert from the existing roster. Together with the expert the PCM Officer will assess the eligibility of the complaint and make a decision on whether or not it should proceed to Compliance Review and/or Problem-solving stage or neither.
The PCM Officer is responsible for the overall, day-to-day operations and external relations of the PCM such as maintaining the PCM web site; registering and preparing administrative procedures and guidelines; receiving and registering complaints and maintaining a documentary record in respect of each registered complaint. The PCM Officer also produces annual reports which cover PCM activities in the respective year.
PCM Annual Reports
Previous editions of the PCM Rules of Procedure
Applicable to complaints received and registered before 7 November 2014