With more than 200 complaints handled in over 20 years, CAO is one of the most experienced independent accountability mechanisms among Development Finance Institutions (DFIs), and our data provides a rich picture of the complaints that arise around development projects.
Despite fluctuations year-on-year, CAO receives an average of 10 new eligible complaints each year, even as IFC has gone through significant growth over the last 20 years. In addition, CAO has triggered 10 compliance reviews during this time.
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Concerns related to project E&S assessment and management are among the most frequently raised in complaints to CAO, along with impacts related to land and resettlement.
Concerns related to a project’s “Environmental and Social Assessment and Management” are raised in 65 percent of complaints received by CAO. These range from the quality of environmental impact assessment to the level of project disclosure and community engagement.
There has been a relatively consistent increase in labor-related complaints since 2007. The region with the largest share of labor-related complaints is Middle East and North Africa, with 6 of the 11 (or 55 percent) complaints received since 2001 raising labor issues.
Concerns about community health and safety, relating to IFC and MIGA Performance Standard 4, have been raised in 42 percent of complaints. In 2021, nearly two in three cases (62%) handled by CAO’s functions raised concerns about community health and safety. Note that the charts show the share of complaints received year-on-year and not the share of open cases handled that year.
Complaints about resettlement and land – including both physical and economic displacement – were received against projects in multiple sectors, but are especially significant in Agribusiness, where three in four complaints raise land-related concerns, and in Mining, Oil, Gas & Chemicals, with 70 percent of complaints raising this issue. “Land Resettlement” corresponds to issues that IFC and MIGA address under Performance Standard 5.
CAO has handled complaints about biodiversity impacts through both the dispute resolution and compliance functions. Slightly more complainants raising biodiversity concerns chose the Compliance process. “Biodiversity” corresponds to issues that IFC and MIGA address under Performance Standard 6.
Nearly all – 97 percent – of complaints that raise concerns relating to Indigenous People also raise broader concerns around Land, while 85 percent raise specific “Land Resettlement” issues. Concerns related to the rights of and potential impacts on Indigenous People are addressed by IFC and MIGA under Performance Standard 7.
Just over half of complaints that raise issues about Cultural Heritage overlap with complaints relating to Indigenous People. “Cultural heritage” corresponds to issues that IFC and MIGA address under Performance Standard 8.
Land – defined more broadly here to include non-resettlement-related concerns ranging from disputed ownership to pollution – is raised in 58 percent of cases.
CAO Spotlight: CAO’s Case Study “A Journey Towards Solutions” highlights CAO’s Dispute Resolution work in Uganda, where land was a significant issue raised in the dialogue process.
Water-related concerns are raised in 40 percent of complaints, most often along with Resource Efficiency and Pollution. Close to 80 percent of complaints that raise water-related issues also raise concerns around Resource Efficiency and Pollution.
Complaints that raise concerns relating to Women or Children make up approximately 15 percent of all complaints. Over 80 percent of such complaints also relate to Community Health & Safety, and in 15 percent of cases, complainants raise concerns about gender-based violence and harassment.
CAO has received complaints from all regions of the world where IFC and MIGA do business. CAO has had a higher volume of complaints from the Latin America and Africa regions, which may correspond to the relatively larger size of the IFC portfolios in those regions.
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Sectors that typically have resource intensive projects with large footprints – mining, oil, gas, and chemicals, or infrastructure – make up a significant share of CAO cases. While this may be expected, CAO also receives complaints from sectors that typically have smaller footprints and/or visibility.
Despite the greater attention these projects receive from IFC, CAO sees a large number of projects that IFC has designated as high-risk (Category A). In IFC’s portfolio, Category A projects make up less than 10 percent of IFC’s long-term commitments as of 2020. More recently, CAO has received a larger number of Category B projects, which represented a share nearly equal to that of Category A projects by 2021.
CAO was designed to be easy for complainants to access and the eligibility criteria for CAO to accept a complaint are simple:
