Independent complaints mechanism

Independent complaints mechanism

FMO has implemented an Independent Complaints Mechanism which allows external parties to file a complaint concerning projects financed by FMO.

The Mechanism ensures the right to be heard for Complainants who feel affected by an FMO-Financed Operation in order to enable resolution of disputes and assist FMO in drawing lessons learned for current and future operations. FMO strives to implement a robust and independent procedure and to communicate transparently about it to stakeholders.

The Mechanism is a joint initiative of DEG - Deutsche Investitions- und Entwicklungsgesellschaft (DEG) and FMO. Since February 2019, the French Development Finance Institution Proparco has also joined the Mechanism.

COVID-19 impact on case handling

The rapidly evolving global situation with COVID-19 is impacting all of us in unexpected ways. The Independent Complaints Mechanism (ICM) sends its sympathies and support to our friends, colleagues, and partners who are being adversely affected by this outbreak. FMO’s business activities keep running. FMO’s staff is working from home. For the time being, travel is suspended worldwide. These rules apply also to the members of the Independent Expert Panel, ICM staff, associates and consultants. In light of these measures, ICM case handling will be adjusted as needed in discussion with the parties.

If you have questions or concerns related to cases in ongoing dispute resolution or compliance processes, please contact us at Thank you very much for your understanding.

Independent Expert Panel

FMO has set up a Complaints Office to administrate and coordinate the work regarding the Complaints Mechanism. The Complaints Mechanism is further supported by an Independent Expert Panel, which decides on the admissibility of a complaint and handles all subsequent processes.

The Panel is formed of three international specialists with expertise and experience in mediation, social and environmental issues, as well as in supporting complaints mechanisms.

picture Inbal.jpgInbal Djalovski

Inbal is a legal practitioner with over 14 years’ experience in both domestic and international law, with expertise in international investigations, human rights and gender equality. Her experience includes working as a Prosecution Lawyer with the Office of the Prosecutor of the International Criminal Court. She previously served as a legal adviser to senior Judges at the Appeals Chamber of the International Criminal Tribunals for the former Yugoslavia and Rwanda. She is admitted to law in New York (USA) and in Israel, and is a graduate of INSEAD and Columbia Law School.

Michael Windfuhr

Michael is a well-known expert on realizing human rights. He co-founded FIAN-International (FoodFirst Information and Action Network) and left the organization as Secretary General to become the Human Rights Director of “Brot für die Welt” (Bread for the World). Michael currently works as the Deputy Director of the German Institute for Human Rights, the national human rights institution of Germany

Arntraud Hartmann

Arntraud has been a Panel Member of the Accountability Mechanisms of the African and Asian Development Banks. From 1981-2004 Hartmann was a staff member of the World Bank where she held senior management positions. She was the first Chief of Mission for the World Bank in Romania (1992-1996), Director for South East European Countries and Senior Advisor to the Managing Director. Hartmann also worked as Fellow with the UNICEF Innocenti Center and was a Senior Advisor to the World Commission on the Social Dimensions of Globalization chaired by the ILO. From 2009 to 2016 she was Adjunct Professor of International Development at the Johns Hopkins University, SAIS Europe, Italy and at the Hertie School of Governance, in Berlin, Germany. Since 2019 she is Steven Müller Professor at  SAIS Europe, Johns Hopkins University.

Complex projects








ICM Annual Reports

Other complaints mechanisms

Related links

Complaints disclosure

Below you find all project-related complaints that have been declared admissible by the Independent Expert Panel as of January 2014.

2020 Nyamagasani I and II HPP

2018 Lome Container Terminal

2016 Sendou

2014 Barro Blanco