How IPAM Works

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How can IPAM address my concerns?

IPAM has two non-judicial and non-adversarial ways through which it can address Requests:

  1. Problem-solving: IPAM facilitates dialogue between Requesters and Clients to resolve environmental, social and public-disclosure concerns without attributing blame or fault. IPAM mediates between Project-affected people, Clients and other stakeholders as a neutral third party to help find mutually satisfactory solutions. In addition to facilitated dialogue and mediation, solutions can be reached through conciliation, information sharing, joint fact-finding or supported negotiation.

  2. Compliance Reviews: IPAM reviews the Project's environmental and social performance of the Bank Project to determine whether the EBRD has complied with its commitments under the Bank's Environmental and Social Policy and Access to Information Policy. The Compliance Review assesses the Bank’s compliance, not the Client’s compliance. IPAM engages with Project-affected people, Bank staff, Clients and other stakeholders to determine the Bank’s compliance. If the EBRD is found to be non-compliant, IPAM will propose changes to the Project and to the Bank's procedures to address the non-compliance, prevent future non-compliance, and promote institutional learning.

IPAM’s mandate is focused on the review of environmental, social, or transparency-related concerns only. However, other complaint mechanisms exist at the EBRD to address other types of concerns. If you have concerns about:

Who can submit Requests for review?

Requests can be submitted by individuals and civil society organisations who believe they are directly and personally affected by an EBRD Project.

In certain circumstances, IPAM can also consider Requests submitted by civil society organisations that are not directly or personally affected. However, in these cases, IPAM will evaluate the specific circumstances of each Request and seek additional information prior to proceeding.

IPAM's commitment to confidentiality 

Requesters may ask that the identities of some or all of the individuals involved in a Request be kept confidential. IPAM is committed to protecting Requesters’ identities, if confidentiality is expressly asked for in a Request. The Requester will be asked to explain why they are looking to address their Request confidentially, so IPAM can seek to respond to concerns and manage the case in an appropriate manner. IPAM does not tolerate retailiation against Requesters or any other individuals involved in an IPAM process or outreach activity, and rejects any form of threat, intimidation, harrassment, violence or discrimination based ont he fact that they have exercised their right to raise concerns.

How do I submit a Request for review?

Requests for Review can be submitted in any written format, using:

EBRD Independent Project Accountability Mechanism
Attn: Victoria Marquez-Mees, Chief Accountability Officer
One Exchange Square
London EC2A 2JN
United Kingdom
Email: ipam@ebrd.com 

Requests can also be mailed or delivered to any EBRD Resident Office in our countries of operation. Simply ask that it be forwarded to the Chief Accountability Officer of IPAM.

Overview of case steps

 

 

 


 

 

Registration: Following receipt of a Request, IPAM will screen the Request against the IPAM registration criteria, to confirm whether it falls within IPAM’s mandate.

 

Assessment: Following the Registration of a Request, IPAM will complete an Assessment in order to:

i.  develop a clear understanding of the issues raised in a Request

ii. discuss the Problem Solving and Compliance Review options, their scope and possible outcomes with the Requesters, the Client and the Bank

iii. assess the Requesters' and Clients' willingness to engage in each Problem Solving or Compliance Review, while taking Requesters’ preferences into account

iv. consider the status of other grievance resolution efforts ( if applicable)

v.  determine if the Case will:

  • proceed to Problem Solving (if the Requesters and the Client agree);

  • be transferred to a Compliance Assessment, if no agreement to complete Problem Solving is reached; or

  • be closed.

 

Problem Solving: IPAM will facilitate dialogue between the Parties, seeking to find jointly-acceptable solutions that resolve the issues raised in the Request.

 

Problem Solving Monitoring: IPAM will monitor the implementation of any agreements reached between the Requesters and the Client through Problem Solving.

 

Compliance Assessment: IPAM will assess whether a Request is eligible for a Compliance Review, considering whether:

i.   it appears that the Project may have caused (or may be likely to cause) direct or indirect and material harm to Project-affected people; and

ii.  there is an indication that the Bank may not have complied with the Environmental and Social Policy or the Access to Information Policy.

 

Compliance Review: IPAM will complete an in-depth review of the Project to identify whether the Bank complied with the Environmental and Social Policy or the Access the Information Policy. If IPAM concludes that the Bank is non compliant with its policy commitments, the Mechanism will recommend remedial Project-specific and systemic actions to bring the Project back into compliance, and to avoid non-compliance on other similar projects. 

 

Management Action Plan Monitoring: IPAM will monitor the implementation of Management Action Plans (i.e. Actions EBRD Management has committed to, in order to address any findings of non-compliance).

 

Target case timelines

 

Stage

Key Activities

Request Receipt
  • Acknowledgement of receipt of the Request: within 10 Business Days of receipt.

Registration

  • Determination on Registration: within 21 Business Days of the date of the Request’s acknowledgement.

    • If additional information is needed from the Requesters for IPAM to make a decision on Request Registration, the Requesters will be granted 15 Business Days to provide the necessary information.

    • If a Request is suspended, the Bank will have a maximum of 45 Business Days to make good faith efforts to address the environmental, social or public disclosure issues raised in the Request, before IPAM considers lifting the suspension.

Assessment

  • Completion of an Assessment and submission of the Assessment Report to the Board: within 40 Business Days of the Registration of the Request.

Problem Solving

  • Completion of Problem Solving: may vary in duration, according to the nature, complexity, and scope of the issues and other factors such as Parties’ engagement and decisions throughout the initiative. The Problem Solving schedule is decided jointly by the Requesters, the Client and other Parties to the initiative.

Compliance Assessment

  • Where IPAM recommends closing the Case – Completion of the Compliance Assessment and submission to the Board: within 60 Business Days of the initiation of the Compliance Assessment by IPAM.

  • Where IPAM recommends proceeding to a Compliance Review – Completion of the Compliance Assessment Report and circulation of the terms of reference to the Parties: within 60 Business Days of the initiation of the Compliance Assessment.

    • Where applicable, Bank management will have 21 Business Days from the date of IPAM’s request to submit a written response to the Request.

    • Requesters, Bank management and Clients will have 10 Business Days from the date of IPAM circulation to comment on the draft terms of reference for the Compliance Review, where applicable.

Compliance Review

  • Completion of the draft Compliance Review Report: within 140 Business Days of the publication of the Compliance Assessment Report.

  • Where IPAM finds non-compliance

    • Bank management will have 30 Business Days from the date of receipt of the draft Compliance Review Report to submit the draft Management Action Plan, and the Management Response, if any)

    • Requesters will have 20 Business Days from the date of IPAM circulation to provide comments on the draft Management Action Plan.

    • IPAM will have 10 Business Days following the receipt of Requesters’ comments on the draft Management Action Plan to finalise the Compliance Review Report.

    • Management will have 15 Business Days from the date of receipt of both the final Compliance Review Report and Requesters’ comments. 

Monitoring

  • Issuance of Monitoring Reports: at least bi-annually, until IPAM determines that full implementation of the relevant Problem Solving agreement or Management Action Plan has been achieved.

  • Bank management will have 10 Business Days from the date of IPAM’s request to submit monitoring updates on Management Action Plan implementation.

 

You can contact us if you have questions about how to write and submit a Request.

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