Independent Complaints Mechanism (ICM)

Proparco purpose is to support private sector development in developing and emerging countries. In order to promote a sustainable and resilient economy, the protection of the planet and the reduction of inequalities, Proparco respects high environmental, social and ethical standards based on human rights, the fight against corruption, transparency, dialogue with its stakeholders and reducing its ecological footprint.

During their deployment, projects may have unexpected or uncontrolled negative effects on the environment and people, including communities, workers or other stakeholders. This is why Proparco has set up an Independent Complaints Mechanism (the ICM).

This mechanism gives any person, local community or group of individuals who feel they have been negatively affected by a project financed by Proparco the opportunity to file a complaint with Proparco, the right to be heard and if necessary, provide access to remedy.

The Independent Complaints Mechanism is a joint initiative of Proparco and the German and Dutch Development Finance Institutions (DFIs); DEG - Deutsche Investitions und Entwicklungsgesellschaft, the German bilateral private sector development bank and FMO - Netherlands Development Finance Company, the Dutch bilateral private sector development bank.

The DFIs commit to regularly review and update, if necessary, the ICM policy in order to ensure its robustness, effectiveness, compliance with best practices, its accessibility and its capacity to adequately carry out the claims process whilst meeting the needs of stakeholders.

New Policy for the Independent Complaints Mechanism 

The DFIs and the ICM Independent Expert Panel led a multi‑year, expert‑facilitated, and consultation‑driven revision of the ICM Policy, working collaboratively from the initial 2022 review through extensive stakeholder engagement and consensus‑oriented drafting. Following a formal public consultation process in 2025, the jointly prepared final ICM Policy was endorsed or acknowledged by the DFIs in December 2025. See the link below for more information on the process that was followed.

• The revised ICM Policy introduces clearer and more predictable processes and timelines aligned with similar accountability mechanisms.
• It strengthens operational independence by replacing DFI‑based complaints offices with a fully independent, three‑member Panel supported by dedicated staff.
• It ensures consistent budgeting, reporting, and governance through a single website (currently under development) and an empowered Panel Chair.
• It expands the mechanism’s functions to include advisory and outreach roles.
• It introduces a formal deferral option for early resolution.
• And it clarifies the treatment of financial intermediaries and establishes time‑bound monitoring tied to management action plans. 

Overall, the final policy shows strong alignment with international standards and enhanced independence.

Implementation and Panel Chair appointment

The final ICM Policy is in effect as of 1 March 2026, after which all newly submitted complaints will be handled under the updated policy. 

The DFIs are pleased to announce that Dr. Marina d’Engelbronner-Kolff, a current Panel Member, has been appointed as the Panel Chair. In her new role, Dr. d’Engelbronner-Kolff will continue to serve as a Panel Member while assuming additional representational, operational, and managerial responsibilities, including oversight of the ICM’s dedicated staff, to ensure the mechanism operates effectively and efficiently.