IPAM stands for Independent Project Accountability Mechanism and is the grievance mechanism of the EBRD. It deals with complaints about environmental, social and disclosure matters related to the Bank’s investments.
The EBRD has the Environmental and Social Policy (ESP), the Access to Information policy (AIP) and the Project Accountability Policy (PAP) to enable sound and sustainable development in its projects.
IPAM is independent from Bank's management, and addresses complaints in two ways: Problem Solving and Compliance Review.
In problem solving, we promote non-adversarial engagement between parties in search of consensual solutions to the concerns raised by the complainants. In compliance review, we undertake fact-finding investigations to determine if the Bank has complied with the environmental, social and disclosure standards set in our ESP and AIP.
IPAM has a mandate to conduct outreach among both internal and external stakeholders, to foster greater knowledge and understanding of its policy and purpose. It will continuously endeavour to engage with project affected communities and civil society organisations in promoting safe access.
Finally, IPAM routinely share the lessons learned and offer guidance to Bank management based on the insights, experiences and evidence emerging from its Casework.
IPAM has the ability to review the Bank's compliance with two EBRD governance policies: the Environmental and Social Policy and the Access to Information Policy. These policies are available at the links below.
Earlier versions of the EBRD's accountability policy were used to review cases handled before July 2020. These historic policies, no longer in effect, are available below for information.
The Independent Project Accountability Mechanism, best known for its acronym IPAM, is the grievance mechanism of the European Bank for Reconstruction and Development (EBRD). IPAM is independent from the Banking team and reports directly to the Board of Directors of the Bank.
EBRD is committed to promoting sustainable development in all of its investments, as a key contributor to economic transition. To ensure that the environmental and social practices of Bank Projects meet EBRD standards, the Bank requires that Projects comply with its Environmental and Social Policy. In addition, the Bank is required to disclose certain Project information to the public in accordance with its Access to Information Policy, to enhance transparency and accountability, improve discourse with affected stakeholders, and foster good governance. IPAM is part of the accountability architecture of the Bank to ensure its compliance to the mentioned policies.
IPAM independently reviews issues raised by individuals or Organisations concerning Bank-financed Projects, which are believed to have caused or to be likely to cause, harm. The purpose of the mechanism is to facilitate the resolution of social, environmental and public disclosure issues among 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 where applicable, to address any existing non-compliance with these policies, while preventing future non-compliance by the Bank.
The Project Accountability Policy or PAP is the policy approved by the Board of Directors in 2019 determining the establishment of IPAM and detailing the structure of the office and the procedure to be followed by the Mechanism to implement its mandates.
IPAM has four functions: Problem Solving (dispute resolution), Compliance Review (investigation), Outreach (promote access) and institutional learning (distil lessons learned based on cases).
In the Problem-solving function, IPAM acts as a neutral third party facilitator when the Requesters, the Client and any other relevant stakeholder agree to engage and seek mutually agreeable solutions to the concerns raised in the request. This is a voluntary, flexible, consensus-based dispute resolution process facilitated by IPAM with the objective of reaching sustainable agreements.
The Compliance function determines whether EBRD has complied with its Environmental and Social Policy or the Project-specific provisions of its Access to Information Policy in respect of a Project. As such, the Compliance function only deals with the compliance of the Bank, rather than the compliance of the Client. IPAM engages with Project-affected People, Bank staff, Clients and other stakeholders in order to determine whether the Bank, through its actions or inactions, has failed to comply with any provision of the Environmental and Social Policy (including any provision requiring the Bank to monitor Client commitments), or the Project-specific provisions of the Access to Information Policy. If EBRD is found to be non-compliant with either of the policies above, the Compliance function also proposes Project-specific and procedural changes to Bank practices to address existing non-compliance, prevent future non-compliance and promote institutional learning and capacity building.
The purpose of outreach is to promote accessibility to IPAM amongst civil society organisations and project affected people and to raise awareness of IPAM’s purpose, functions and activities amongst EBRD staff, clients and other relevant stakeholders.
IPAM will routinely share lessons learned with Bank management and produce knowledge products based on the insights, experiences and evidence emerging from its casework. In this function, IPAM promotes a culture of continuous learning at EBRD.
In addition to conducting its case processing in an impartial fashion, regardless of any attempts at undue influence from any third party, independence in IPAM is accomplished structurally by:
Giving responsibility to the CAO for running IPAM, implementing the Project Accountability Policy and making the decisions that are within the IPAM mandate.
Determining that the CAO is not part of, and does not report to, Bank management. It reports directly to the Board.
Establishing that candidates for the CAO position cannot have worked for the Bank in the five years prior to the selection and are banned for working for the Bank at the end of their term.
Giving authority to the CAO for preparing an annual budget and determining the allocation of resources within IPAM. The Board, not Bank Management, approves the budgetary request.
Determining that the CAO is free to make recruitment decisions within the limits of the approved budget.