How can IPAM address my concerns?
IPAM has two non-judicial and non-adversarial ways through which it can address Requests:
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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.
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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. Other types of concerns are addressed by alternative units of the Bank. If you have concerns about:
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Fraud, corruption, ethical behaviour or staff/ client misconduct: please submit complaints to the Office of the Chief Compliance Officer at whistleblowing@ebrd.com
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Procurement issues: please submit complaints to the Procurement Policy and Advisory Department at Procurement@ebrd.com
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Other questions or concerns: please submit complaints to the EBRD’s Civil Society Engagement Unit at cso@ebrd.com
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
IPAM is committed to protecting Requesters’ identities, when confidentiality is expressly asked for. Requesters have the right to ask for the identities of some or all of the individuals involved in a Request to be kept confidential. The Requesters will be asked to explain the reasons why confidentiality is requested. This is to assist IPAM to determine course of action to be taken in relation to case processing . IPAM does not tolerate retaliation against Requesters or any other individuals involved in an IPAM process or outreach activity, and rejects any form of threat, intimidation, harassment, violence or discrimination based on the fact that they have exercised their right to raise concerns.
How do I submit a Request for review?
Requests can be submitted in any written format, using:
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IPAM’s secure, encrypted online Request Form, available on the IPAM website in English, in Russian русский and in Arabic عربى
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email or mail:
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 for your Request to be forwarded to the Chief Accountability Officer.
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. A decision will be issued within 21 business days of receipt of request
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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.
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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: 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)
An Assessment Report is issued within 40 business days of the date of registration, presenting the outcome of the assessment, which can be any of the following:
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proceed to Problem Solving (if the Requesters and the Client agree);
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be transferred to a Compliance Assessment, if no agreement to complete Problem Solving is reached; or
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be closed.
Problem Solving: IPAM will facilitate engagement between the Parties, seeking to find jointly acceptable solutions to the issues raised in the Request. This is a voluntary process with an expected timeframe of 1 year.
Problem Solving Monitoring: IPAM will monitor the implementation of any agreements reached under the Problem Solving Initiative.
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.
A Compliance Assessment Report is issued within 60 business days of the initiation of this stage.
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Where applicable, Bank management will have 21 Business Days from the date of IPAM’s request to submit a written response to the Request.
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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: IPAM will undertake a fact-finding investigation based on the case terms of reference. During the compliance review, IPAM will:
i. Discuss with the Requesters, Bank management, the Client and other stakeholders;
ii. Undertake a site visit, unless deemed unnecessary by IPAM;
iii. Engage consultants on specific technical matters, if deemed necessary by IPAM.
Upon the completion of the compliance review, IPAM prepares a Compliance Review Report that presents its findings and specific recommendations to address the findings of non-compliance.
The expected timeframe for IPAM to complete the investigation and produce a draft report is 140 business days.
If IPAM finds non-compliance, an opportunity for comments from Parties and finalisation of the report follows:
First, 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);
Then Requesters will have 20 Business Days from the date of IPAM circulation to provide comments on the draft Management Action Plan.
After that, IPAM will have 10 Business Days following the receipt of Requesters’ comments on the draft Management Action Plan to finalise the Compliance Review Report.
Finally, Management will have 15 Business Days from the date of receipt of both the final Compliance Review Report and Requesters’ comments.
The finalised Compliance Review Report and Management’s Action Plan are then submitted to the Board who is responsible for approving the plan presented by Management. After that, these documents are disclosed in the IPAM Case Registry.
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) until it deems the actions completed.
For Management Action Plans to be considered implemented they must fulfil the following criteria:
i. the implementation plans and commitments set out thereunder are being effectively carried out; and
ii. implementation timetables are being met.
IPAM will issue Monitoring Reports bi-annually, describing monitoring activities undertaken by IPAM, and providing updates on the implementation of the Management Action Plan.
You can contact us if you have questions about how to write and submit a Request.
