Policy Review

EBRD's Project Accountability Policy (2019) superseded the 2014 Project Compliance Mechanism Rules of Procedures and became effective with the appointment of its first Chief Accountability Officer on 1 July 2020.  

PAP establishes the Independent Project Accountability Mechanism (IPAM). With the introduction of IPAM, the EBRD has greatly improved its accountability; in terms of its role and mandate, senior leadership, reporting lines directly to the Board, internal expertise, a clear process, and timelines establishing predictability on case processing for concerned parties.

The purpose of the policy is to facilitate the resolution of social, environmental and public disclosure issues among the project stakeholders; to determine whether the bank has complied with its Environmental and Social policy and the Project specific provisions of its Access to Information Policy; and wherever applicable, to address any existing non-compliance with these policies, while preventing future non-compliance by the Bank.

Section VIII of the policy mentions that the policy shall be reviewed in 2024. 

In early 2023, IPAM presented its approach to the review to the Board, Management and Civil Society Organisations, which proposed the following:

The key objectives of the Policy review are: (a) to clarify language if the current provisions lead to divergent interpretations that affect Policy implementation and mandate; (b) to adjust Policy provisions when implementation shows that there are areas of improvement as regards effectiveness and/or efficiency; and (c) to incorporate best practices in accountability.

At the end of stage 1, IPAM will produce two main outputs:

• An assessment of the implementation of the PAP.
• A recommendation on how to proceed and suggested focused policy topics subject to review.  

IPAM commissioned on December 2023 external expert Zeinab El-Bakri (former member of the World Bank’s Inspection Panel) to undertake an external assessment of the implementation of the PAP by IPAM. The Terms of Reference of the Consultancy are below. In April 2024, the external consultant submitted her report to the Audit and Risk Committee. 

The first stage has been completed, find the External Assessment Reports below. 

IPAM is committed to engaging with all stakeholder groups at different stages of the assessment and review process.

As regards the first stage of the process, IPAM’s engagement and consultation are focused on views regarding implementation and whether the current Policy is still fit for purpose.

• From December 2023 to January 2024, the external assessor engaged with a small sample of every stakeholder group (56 individuals) to gather their views. The External Assessment Report is available in English and Russian.
• From June to end of August 2024, IPAM will be reaching out via email to a wide group of individuals and organisations that have been actively engaged in IPAM cases, to gather their views on how best to address the findings of the External Assessment Report and next steps.

This section will be updated once the results of this first stage of consultations is completed.

IPAM operates according to the provisions set out in the 2019 Project Accountability Policy (PAP) and its associated Guidance on Case Handling. These documents describe:

• IPAM's mandate, guiding principles, structure and governance.
• Who can submit a request, how to submit and what information must be provided for processing.
• The process that IPAM follows to address the concerns raised.
• The criteria for decision making and the timelines of each of the stages in case processing.